The national radioactive waste dump the federal government wants to establish near Woomera in northern South Australia (SA) will be the thin edge of the waste wedge:
- the dump will take not only low-level radioactive waste but also short-lived intermediate-level waste, not only short-lived waste but also long-lived waste;
- it will take not only lightly-contaminated lab coats, smoke detectors etc., but also radioactive components from nuclear reactors at Lucas Heights when they are dismantled;
- an above-ground store for long-lived intermediate-level waste (LLILW), including waste from the reprocessing of the Australian Nuclear Science and Technology Organisation's (ANSTO) spent reactor fuel, may be ‘co-located’ adjacent to the dump;
- the ‘interim’ LLILW store may become a permanent fixture, or a deep underground dump or some other "purpose-built facility" may be established for LLILW disposal;
- ANSTO has said that unprocessed spent fuel could be sent to the LLILW store for “extended interim storage” if overseas reprocessing plans fall through, and the federal Department of the Environment and Heritage said in 1999 that storage at an unspecified “remote repository” would be the “only prudent and feasible alternative” consistent with government policy if overseas reprocessing plans fall through;
- a spent fuel processing/conditioning plant may be built in Australia in the coming decades, and sites in SA would certainly be short-listed (as they were in a 1997 siting study); and
- there remains a small possibility that above-mentioned developments will pave the way for a deep underground dump for tens of thousands of tonnes of high-level waste from nuclear power plants overseas.

The federal government's mantra is that the dump is for low-level radioactive waste - relatively innocuous things such as radium watch faces, household smoke detectors, exit signs and laboratory waste stored in several dozen locations around Australia. However, the government's primary agenda is to remove waste from the ANSTO reactor plant at Lucas Heights in southern Sydney in order to reduce opposition to a new reactor. ANSTO is by far the single largest generator of radioactive waste in Australia (excluding uranium mines, where waste is stored on site).

So it's not just old lab coats and smoke detectors, but also dismantled nuclear reactor components - and much else besides from Lucas Heights - destined both for the SA dump and for a planned above-ground LLILW store. The federal government says that it "will ensure that all radioactive waste is removed from Lucas Heights in a staged process, once the repository and [LLILW] storage facility are established." (Government response to the report of the Senate Economic References Committee's 1997-99 reactor inquiry, Senate Hansard, 6/4/00, p.13062.)

The largest of the two existing reactors at Lucas Heights, HIFAR, will generate 500 cubic metres of waste for the planned Woomera dump (Department of Industry, Science and Resources (DISR), July 2001, “Australia’s radioactive waste: what it is”). The other reactor, Moata, is awaiting decommissioning. The planned new reactor will eventually be shut down and dismantled and may also be dumped in SA.

The government will not establish waste acceptance criteria to determine what can/can't be dumped at Woomera "until some time in the future" according to a consultancy firm commissioned by the federal government (CH2M Hill, September 1998, Replacement Reactor Draft EIS Technical Review, p.17).

There is no accurate inventory of the radioactive waste stored around Australia which might end up in the planned Woomera dump. Crude data on waste volumes and types will probably be released by the government, and dressed up as a national inventory, but it’s unlikely that accurate figures on radioactivity, radionuclidic composition and concentrations, and radiation types (alpha, beta, gamma) will be compiled and publicly released.

Nuclear engineer Alan Parkinson noted in a 2001 paper that: "A reading of the various publications on the subject of the low level waste repository published by the department [of industry, science and resources], coupled with statements made in the electronic media, suggests that there is no agreement within the department nor with other Australian nuclear organisations as to the definition of the various levels or categories of waste." (Comments on DISR / National Store Advisory Committee, July 2001, "Safe Storage of Radioactive Waste, The National Store Project: Methods for choosing the right site.)

Government literature reveals that in addition to waste classified as low-level, the SA dump will also take short-lived intermediate-level waste. Likewise, when the government says the dump is for short-lived waste, it means waste containing short-lived radionuclides, long-lived radionuclides, and short-lived radionuclides which decay to form long-lived radionuclides. (For example, this is the decay chain for curium-242, half life 162.8 days - plutonium-238, 87.74 years; uranium-234, 244,500 years; thorium-230, 77,000 years; radium-226, 1,600 years; radon-222, 3.8 days; polonium-218, 3 mins; lead-214, 26.8 mins; bismuth-214, 19.9 mins; polonium-214, 164.3 microsecs; lead-210, 22.3 years; polonium-210, 138.38 days.)

The federal-government-commissioned consultancy firm CH2M Hill found ANSTO's conflation of short-lived and long-lived waste to be "nonsensical" (CH2M Hill, September 1998, Replacement Reactor Draft EIS Technical Review, p.15).

The latest waste classifications from the government leave further wriggle-room (e.g. DISR / National Store Advisory Committee, July 2001, "Safe Storage of Radioactive Waste, The National Store Project: Methods for choosing the right site). For example, low-level waste is said to include "low levels of beta and gamma emitting, and normally very low levels of alpha emitting radioactive material". What is a "low" level or a "very low" level, and who decides? What is meant by the term "normally" - Mondays to Fridays inclusive? Intermediate level waste is said to contain "significant levels of beta and gamma and possibly alpha emitting radioactive material". What is a "significant" level, and who decides?

Maralinga

Waste containing long-lived radionuclides is not suitable for shallow burial according to government documents (e.g. DISR / National Store Advisory Committee, July 2001, "Safe Storage of Radioactive Waste, The National Store Project: Methods for choosing the right site.)

However, this is precisely what happened with the 'clean-up' of the Maralinga weapons test site in north-west SA in the late 1990s.

Parkinson wrote in his 2001 paper: "Whether the plutonium contaminated wastes at Maralinga are low level or intermediate level, they cannot be claimed to be short-lived. Hence, according to the department’s [DISR’s] own definitions ..., what has been done at Maralinga in the disposal of such waste in a (very) near-surface burial is not acceptable. Having said that, how can anyone place any confidence in the department's management of the proposed waste repository and store? The burial of plutonium, which will remain hazardous for the next 250,000 years or so, in a (very) near-surface burial at Maralinga has established a precedent for disposal of waste that has very much shorter half-lives than plutonium in a simple hole in the ground. What guarantees are there that this 'solution' will not be adopted for any radioactive waste? ... The outcome of the Maralinga project is clear evidence that neither the Minister [Nick Minchin], his department, nor ARPANSA [the Australian Radiation Protection and Nuclear Safety Agency] have any credibility in the management of radioactive waste ..." (Comments on DISR / National Store Advisory Committee, July 2001, "Safe Storage of Radioactive Waste, The National Store Project: Methods for choosing the right site.)

'Code of Practice'

The government says the dump will comply with the 1992 NH&MRC Code of Practice for the Near-Surface Disposal of Radioactive Waste in Australia. This is no comfort since, according to Parkinson, DISR (and ARPANSA) falsely claimed that the Maralinga clean-up complied with the code: “The department has claimed that burial is a safe disposal method consistent with ‘the Code.’ ... When three of the five authors said that it was not applicable (the other two were Commonwealth public servants and would not comment), the Department claimed that it did not have to follow the Code but had chosen to do so. It made this statement despite the fact that not a single requirement of that Code was satisfied.” (Alan Parkinson, February 2002, “Maralinga: The Clean-Up of a Nuclear Test Site”, Medicine and Global Survival, Volume 7, Number 2, <www.ippnw.org/MGS>. See also Alan Parkinson, 2000, “Maralinga Rehabilitation Project”, <www.mapw.org.au/conferences/mapw2000/papers/parkinson.html>.)

The 1992 code says that "prior to disposal operations, the appropriate authority shall establish a limit on the total radionuclide activity for the proposed disposal facility." So what will the limit be for the planned dump? The government refers that question to ARPANSA, and ARPANSA refers the question back to the government. Whatever the limit on total radioactivity, radioactive decay will allow dumping to continue indefinitely without the limit being exceeded.

The minister for industry, science and resources, Nick Minchin, said in a January 24, 2001 media release: "Over a 50 year working life, Australia would have less than 10,000 cubic metres of low level waste to dispose of in the repository." But Minchin's own department said that that the dump could be open for business for longer. A 2001 DISR information sheet said: "The operational lifetime of the repository is expected to be 50 years, but disposal may continue beyond then, subject to the outcome of the review to be undertaken at that time."

LLILW store

Minchin said that concerns about a low-level dump becoming the thin edge a nuclear waste wedge reflected some people's "mindless determination" to stop the dump being built (Hansard, 7/2/2000, Economics Legislation Committee, p.80). However, government literature clearly indicates that the federal government has bigger things in mind for the Woomera dump.

In 1997, a Commonwealth/State Consultative Committee on the Management of Radioactive Waste meeting decided that the "first siting option" for an above-ground store for LLILW - including waste arising from reprocessing of the spent fuel from the Lucas Heights reactor - would be to "co-locate" it adjacent to the planned low-level dump.

The co-location plan was downplayed and often ignored altogether when the federal government began selling its plan for a low-level dump in northern SA in early 1998. For example, in a letter in the November 23, 1999 Advertiser, Minchin said co-location was "one" option and he said that the Consultative Committee identified co-location as a "possible" option. No mention of co-location as a "first siting option".

On May 17, 2000, the SA Liberal government announced that it would legislate in an attempt to stop the federal government storing LLILW in SA, and that legislation is now in place.

The federal government threatened to over-ride the state legislation (e.g. Minchin, 18/5/00, media release), but in February 2001 the federal government ruled out co-location and shifted the problem of a site for a LLILW store to an 'expert' committee which will report later this year.

It was only a partial back-down from the federal government, however. The federal government did not rule out siting the LLILW store elsewhere in SA (or over-riding the SA legislation in the process). Nor did the federal government rule out using the Commonwealth Lands Acquisition Act to compulsorily acquire land. The Coalition federal government, and the SA Liberal Party (now in opposition), both still support the plan for a low-level dump near Woomera.

But legislation is likely to pass through the SA parliament this year attempting to ban the low-level national dump as well, following the introduction of a bill by the new Labor government on May 9. Federal science minister Peter McGauran has repeatedly threatened to over-ride the SA parliament in relation to the low-level Woomera dump (e.g. on ABC Radio National's Earthbeat program, 23/3/02).

Earlier this year, McGauran appeared to reverse the decision not to co-locate the LLILW store adjacent to the planned dump (e.g. the April 6, 2002 Advertiser quoted McGauran saying, "We're not ruling out or ruling in anything.") This prompted a hostile editorial in the Advertiser on February 28: "The renewed threat to override state legislation to establish a long-lived intermediate waste dump here reeks of complete disdain for the Federal Government's supposed role as a servant of the people. That Government lost its right to establish the intermediate dump here when it tried to foist it upon the SA outback in secret. It was only when the extent of the plan was made public, that the tonnes of dangerous waste at Lucas Heights were destined to come here, did the Government attempt to rationalise its case. It was too late then. It is later now. ... In SA, No means No."

Co-location has since been ruled out again. But for how long will co-location be off the government's agenda this time - if it's off the agenda at all? Whatever the latest spin from Canberra, South Australians have every reason to suspect that the low-level dump will attract a LLILW store.

'Extended interim storage' of spent fuel

ANSTO said in 1998: "In the unlikely event that the overseas options [for reprocessing of spent nuclear fuel] should become unavailable, it would be possible at short notice to take advantage of off-the-shelf dry-storage casks for extended interim storage at the national storage facility". (Draft EIS, p.10-18)

The government insists that the LLILW store would not be used for storage of untreated spent fuel, and ANSTO now denies the need for any contingency plan in the event that overseas reprocessing options fall through. But interim storage of untreated spent fuel at the LLILW store remains a possibility. There may be little alternative. The federal Department of the Environment and Heritage said in 1999: "The only prudent and feasible alternative, consistent with the Government's policy to minimise fuel arisings at Lucas Heights and not to undertake reprocessing in Australia (and assuming that there were to be delays in organising reprocessing), would appear to be short-term storage of any arisings beyond nine years, for the proposed reactor, at a remote repository." (Environment Assessment Report on new reactor plan, 1999, chapter 7.8.5.).

Reprocessing/processing/conditioning

If ANSTO finds itself without an overseas organisation willing to reprocess its spent fuel, the issue of domestic reprocessing comes to the fore. It is by no means certain that ANSTO will be able to send spent fuel to France (Cogema), Argentina (Invap/CNEA) or elsewhere over the lifetime of the planned new reactor (ARPANSA Nuclear Safety Committee, February 2002, “Report on the ANSTO Application for a Licence to Construct a Replacement Research Reactor, pp.75-85). Previous plans have had to be abandoned (e.g. reprocessing in Dounreay, Scotland) or delayed (e.g. the 1993 rejection of an application to send spent fuel to the United States).

In 1996, ANSTO did not believe that any overseas option would be available: "As an alternative to overseas shipments, a facility could be built in Australia to condition the spent fuel for ultimate disposal in an intermediate level waste repository. The costs of this alternative are estimated to be comparable to those overseas (reprocessing) options. A domestic conditioning facility also has the advantage that it is the only option that would provide for future spent fuel arisings from any replacement reactor to HIFAR, at which time it is expected that the overseas options will no longer be available." (ANSTO, May 1996, Radioactive Waste Management Policy Preliminary Environmental Review.)

Reprocessing is prohibited in Australia under the federal Australian Radiation Protection and Nuclear Safety Act 1999. However, other processing/conditioning processes are not prohibited. These processes might differ little from reprocessing except that enriched uranium and plutonium would not be separated from the spent fuel. As with reprocessing, they may pose significant environmental and public health hazards, and they might be contentious vis-a-vis the spread of re/processing technology and weapons proliferation.

An April 1998 Department of Industry, Science and Tourism internal briefing paper, obtained by Sutherland Shire Council under freedom of information legislation, revealed that the government did not want to close off the option of building a domestic reprocessing plant: "We may look at new technologies to deal with spent fuel at a later date. ... Do not mention a reprocessing plant."

So domestic processing will be back on the agenda in the coming decades, but the public is to be kept in the dark about this. A senior Canberra bureaucrat was more forthcoming on ABC radio on March 29, 1998: "Cabinet considered reprocessing, but decided it was an issue for another generation. ... 2015 they've got to worry about their spent fuel rods. Someone else can worry about it. And reprocessing is a possibility then... but that's 20 years away. ... The big ticket item was the new reactor and it was felt that politically you just couldn't win the reprocessing argument and the new reactor." (<www.abc.net.au/rn/talks/bbing/bb980329.htm>)

Where might a processing plant be located? ANSTO's executive director Helen Garnett has said that Lucas Heights would be a "reasonable" location for a pilot reprocessing plant (12/11/97, Estimates Committee Hansard, pp.387-397). It is also possible that ANSTO's plan to use Synroc to immobilise medical isotope target waste at Lucas Heights could evolve into a processing plant for both spent fuel and isotope targets.

However, the political cost of trying to force a spent fuel processing plant on Sydney residents could be overwhelming, and (for what its worth) the federal government has ruled out that option in order to minimise opposition to the planned new reactor.

South Australian sites would certainly be on the short-list for a processing plant. A confidential July 4, 1997 Department of Industry, Science and Tourism paper on possible sites for a new reactor and a spent fuel processing plant, also obtained under freedom of information legislation by Sutherland Shire Council, short-listed sites in SA. The Mount Lofty Ranges or "farming areas east of the ranges", and Rangehead (near Woomera), were considered as sites for a new reactor and a processing plant. Olympic Dam was considered for a processing plant. (Other sites considered were Lucas Heights, Holsworthy, Goulburn, Perth, Broken Hill, Mt Isa and Darwin.) (Department of Industry, Science and Tourism, July 1997, "Siting Cabinet Submission".)

The government decided to build a new reactor at Lucas Heights and to leave the issue of spent fuel processing "for another generation", but the confidential siting submission is indicative of the plans which may be pursued in the coming decades.

Deep underground dump

How long would the store accept LLILW waste for? In the course of a presentation in December 2001, Caroline Perkins, a bureaucrat in the Department of Education, Science and Training, said the store will be open for "up to" or "at least" 50 years, after which a deep geological repository would be built or an alternative store established (ARPANSA public forum, Sydney, 14/12/01).

ANSTO appears to be of the opinion that the proposed national store for LLILW is equivalent to final disposal (e.g. Draft EIS, p.10-6, diagram), and an April 2002 Department of Education, Science and Training paper says that the federal government will develop a "purpose-built facility" for the disposal of LLILW without specifying a deep underground dump (Department of Education, Science and Training, April 2002, Safe Storage of Radioactive Waste: The National Store Project: A Report Responding to Public Comment, p.29.)

However, numerous government documents have stated that the LLILW store is an interim measure and that LLILW is destined for disposal in a deep underground dump (e.g. Department of the Environment and Heritage, 1999, Environmental Assessment Report into Proposed Nuclear Research Reactor at Lucas Heights; Department of Primary Industries and Energy, 1998; DISR / National Store Advisory Committee, July 2001, "Safe Storage of Radioactive Waste, The National Store Project: Methods for choosing the right site; DISR, 1998, submission to the Senate Economics References Committee).

The government will sell the LLILW store as an “interim” plan in order to reduce public opposition. But it may become a permanent fixture or it could pave the way for a deep underground dump or some other "purpose-built facility" in the same location. The scientific criteria for the planned above-ground LLILW store and a deep dump are very different, but such criteria can be (and have been) twisted to suit political ends, e.g.:
- the government has used the fact that about half of Australia’s low-level waste (by volume) is already stored above ground at Woomera as one reason to site the dump in SA, yet the criteria for above-ground storage and shallow burial are very different (see for example Senator Nick Minchin, June 2000, “Radioactive waste: The eight biggest myths”, Myth 2: That South Australia can choose not to have radioactive waste.)
- the government acknowledges that long-lived waste is not suitable for shallow burial, but that is what happened at Maralinga.

High-level waste

Another possibility, albeit an unlikely one, is that a deep underground dump for LLILW waste generated in Australia could pave the way for an international dump. In January, Pangea Australia, the company hoping to dump 75,000 tonnes of high-level waste in Australia, closed its Australian offices, but Pangea spokesperson Marcis Kurzeme told the January 24 West Australian that plans to use Australia as an international dumping ground for high-level waste have not been abandoned. A Pangea clone known as the Association for Regional and International Underground Storage (ARIUS) has already been formed, with former Pangea CEO Charles McCombie now working as the managing director of ARIUS. Pangea and its consultants considered regions of SA as potential sites for a deep underground dump for high-level waste.