Transportation and storage of nuclear waste
July 17, 2003
FBEU submission to
the NSW Parliamentary Inquiry into
the Transportation and Storage of Nuclear Waste
The NSW Fire Brigade Employees’ Union (FBEU) is an industrial organisation
registered under the Industrial Relations Act 1996. It represents permanent and
retained firefighters across the State of NSW and has members throughout all
services including the NSW Fire Brigades, the Rural Fire Service and private sector industrial brigades. Formed in 1910, the Union is the most established and democratic organisation representing the interests of firefighters in this State.
The New South Wales Fire Brigades (NSWFB) employ the vast majority of the FBEU’s membership. The NSWFB carries the legislated responsibility as the combat agency for hazardous material incidents in the state of New South Wales. Therefore FBEU members will be the first responders to any incident involving nuclear waste and will be responsible for rendering any incident safe.
The Australian Council of Trade Unions (ACTU) has resolved to oppose the establishment of a national nuclear waste dump and has called on all affiliated unions to support the ban on construction of and provision of services to any proposed dump.
It should also be noted that the FBEU maintains a policy position of opposing the existing ANSTO facility as well as opposing the construction of the replacement research reactor at Lucas Heights, the primary source of existing and future nuclear waste.
It follows that the FBEU believes that any proposal from the Commonwealth Government involving the transportation of nuclear waste represents an unnecessary and avoidable danger imposed on our membership.
Present Storage Arrangements
ANSTO currently retains approximately 1320 cubic metres of low level and short- lived intermediate level radioactive waste at the facility at Lucas Heights. From the perspective of Emergency Service Organisations (ESO), this lamentable fact does provide some advantages in the event of a hazardous materials (HAZMAT) incident involving radioactive materials.
The initial aim in controlling any HAZMAT incident is to contain the release of the substance. The ANSTO site at Lucas Heights is classified by the NSWFB as a Major Hazard Facility. A Major Hazard Facility sensibly attracts attention from ESO’s for all the right reasons. Along with that classification comes extensive preparation by ESO’s for a potential incident involving planning and training for a multi-agency response.
The ANSTO site has a 1.6km buffer zone around the perimeter affording professional firefighters some opportunity in containing a HAZMAT incident involving a release of radioactive materials. Of further advantage to professional firefighters is the ability to work with the operators of the site and industry response teams in developing Pre Incident Plans (PIP) specific to the hazards of the site.
These PIP’s contemplate, and in some cases provide for, the strategic placement of resources in order to ensure that a response to an incident is timely and adequate in terms of capability.
In recent years terrorism has emerged as a real threat to citizens and particularly to professional firefighters. FBEU members are now seen as the first line of civil defence in the event of a terrorist attack. Professional firefighters recognise the the superior ability to secure the Lucas Heights site and understand the particular advantage this ability presents in containing an obvious risk during uncertain times. Of considerable concern to professional firefighters is the possibility that groups associated with terrorist activities may target trucks transporting nuclear waste in order to advance their aims and objectives. There is, in our opinion, simply no way of providing similar levels of security once waste has left the site on the back of a truck.
The FBEU contends that the storage of nuclear waste on one site, being the site where the vast majority of that waste is generated and a site where the resources are best placed to deal with a hazardous materials emergency provides the most effective level of risk minimisation.
This view is supported by recent events internationally. Having grappled with the issue of transportation of nuclear waste for many years, the Republic of Germany has now reverted to on-site storage.
It is then very difficult for our members to understand why the Commonwealth Government effectively plans to shoot holes in this contained and controlled repository in transporting its unnecessary detritus through the largest city of Australia and across the breadth of New South Wales. In doing so, the Commonwealth Government will be transporting a clearly dangerous substance through an uncontrolled, and uncontrollable, environment.
The risks posed for the environment, agriculture and a significant portion of the state’s population would, in a moment of clear thinking, militate against intentionally liberating nuclear waste from a site that provides some opportunity for professional firefighters to prevent an unnecessary threat to life, property and the environment.
Professional firefighters and competent fire service administrators have, for very good reason, not previously contemplated such a possibility. Taking nuclear waste from a controlled storage site and spreading the risk across the state is, in our opinion, an avoidable risk. Therefore we view such a proposal as both reckless and a grossly stupid option for any government to contemplate.
Future Storage Arrangements
The proposed National Repository near Woomera SA will be opposed by this Union in an effort to ensure that no transportation of low level or short lived intermediate level nuclear waste takes place. Of even greater concern is any future proposal for a medium level nuclear waste repository in the state of NSW.
The ‘do-nothing’ option is to leave the low-level waste on site at Lucas Heights. The problem with this approach is that the construction of the replacement reactor ensures that low and medium level waste will continue to be generated. Secondly, the decommissioning and dismantling of the old reactor will produce a significant amount of waste.
Thirdly, the current practice of transporting spent fuel rods to Port Botany for the purposes of offshore reprocessing already presents an unpredictable and unmanageable risk for ESO’s and the citizens of Sydney.
Obviously, there will come a time when the generation of waste exceeds the storage capacity of Lucas Heights. Up until that time is reached the ‘do nothing’ option poses a steadily increasing risk for firefighters and the public. If the safety of firefighters and the public were at all given prominence by the Commonwealth Government the only logical solution would be to cease producing waste.
Firefighters understand that the best approach, where possible, is to eliminate risk. Where that is not possible, the risk must be managed.
The FBEU is familiar with the options proposed in the Draft Environmental Impact Statement (Chapter 7- Transport of Waste to the Repository). It is noted that the majority of existing and future waste has and will continue to be generated by the ANSTO facility at Lucas Heights. Therefore the greatest number of truck movements proposed would be from Lucas Heights to the Repository and that waste will be conveyed along the routes proposed in 7.25 (Sydney to Repository).
The Union believes it logical to assume that the routes proposed in both Option 1 and Option 2 will be used at some stage in transporting waste from Lucas Heights. Even if Option 1 is preferred for the transportation of waste from Lucas Heights Option 2 is a default option that may be utilised depending on climatic conditions, likely community protests or in other circumstances that are yet to be identified. It is also clear that waste sourced from the Australian Capital Territory would be transported along the route proposed in Option 2.
Similarly, transportation options from Brisbane to Repository, Melbourne to Repository and Hobart to Repository will result in waste moving through many cities and towns in New South Wales.
It is of significant concern to professional firefighters that the Commonwealth Government indicates there are no plans to inform emergency services of shipments of nuclear waste. At present, firefighters are not notified of shipments of spent fuel rods to Port Botany. As a direct result, Emergency Service workers, the public and the environment are exposed to significant risk. Firefighters responding to a transport accident involving nuclear waste must be aware of the presence of radioactive material in order to deal with the incident in the most effective and safe manner.
It is assumed that all vehicles carrying radioactive material will comply with the requirement to display a placard on that vehicle indicating the presence of radioactive material. In the event of a transport accident involving fire or significant damage to the vehicle these placards are likely to be obscured or damaged rendering identification impossible. For this reason, firefighters must have other means of identifying any potential danger to themselves, the public and the environment.
The Commonwealth Government’s attitude of keeping professional firefighters and other ESO’s ‘in the dark’ is entirely unacceptable from the perspective of Occupational Health and Safety and represents a serious and inexplicable threat to firefighters, local communities and the environment.
The FBEU and its counterparts interstate foreshadow nationwide industrial action directed against the Commonwealth Government unless the current position is reviewed and the Commonwealth undertakes to ensure emergency services are notified of each and every shipment of nuclear materials.
Should the construction of the repository proceed and transportation of nuclear waste commence it will then require fire services to replicate expensive and highly specialised resources in every town and city that might be affected by a transport emergency involving radioactive materials. At present, the vast majority of professional firefighters do not have timely access to the necessary equipment nor do they have the appropriate training to effectively deal with an incident involving nuclear waste.
The inventory of HAZMAT Response Vehicles includes basic radiation monitoring equipment. These vehicles are located in Greenacre (Sydney), Shellharbour (Wollongong) and at Newcastle.
The only fire stations in NSW that possess radiation monitoring equipment are those tasked as the first responders to ANSTO at Lucas Heights, namely, Menai and Engadine. From the moment transportation commences many more fire stations will be required to envisage a new role as a first responder to a radiological incident.
Basic Chemical, Biological and Radiological (CBR) training has been delivered to a section of our membership but the extent of training is not deemed to be sufficiently widespread nor intensive enough to provide a safe and effective response to a transportation accident involving radioactive materials.
In the event that the transportation proposal goes ahead professional firefighters will require substantial and ongoing CBR training in order to deal with incidents that, in all reality, can and should be avoided.
The concerns of the public about the level of service provided by firefighters in regional areas should be acute. Any expectation by the public that firefighters can provide a level of service commensurate to the risks faced in transporting waste are presently unable to be met in major metropolitan areas. Staffing, resources and long response times over large distances in regional NSW render any notion of an effective response in these areas to the realms of fantasy.
In addition to the upgrades required at existing fire stations 24 hour staffing by specialist crews of dedicated HAZMAT Response Vehicles would be required at specific locations along the transport route. As a basic guide, Annexure ‘A’ details which fire stations would require additional resources and upgrades of staffing, appliances and training.
The Union understands that ANSTO has previously provided funding to the NSWFB for costs associated with the operation of Menai Fire Station. ANSTO has in the past recognised that a quick and effective response by firefighters to the dangers created by their industry requires some financial contribution from ANSTO.
Given that the majority of the waste generated is the responsibility of ANSTO, the FBEU contends that if firefighters are to be required to deal with unnecessary waste generated by the activities of an unnecessary industry then ANSTO’s previous inclination to self fund their own follies should be revisited. ANSTO, along with other generators of nuclear waste, should foot the bill for any measures that are required to be implemented in order to deal with that waste.
The FBEU wishes to make it abundantly clear that it is not our view that the people of NSW nor any agency of the State Government should be required to meet any expenses related to the Commonwealth Government’s proposal to transport nuclear waste throughout NSW.
Significant sums of public money will be required to provide basic protective measures against the threat to firefighters and to the citizens of NSW proposed by the Commonwealth Government. The people of NSW should not suffer reduced services in order to fund the capital and recurrent drain on the NSWFB’s budget caused by the necessity to protect the community against a completely unnecessary threat.
At present the NSWFB is struggling to meet the reasonable needs of a rapidly growing population that requires the expansion of emergency services. Any further burden imposed by the Commonwealth Government will logically retard future expansion at a time of critical community need.
Therefore, the FBEU proposes that in the event of the Commonwealth Government’s proposal proceeding a specific fire brigade levy should be applied to ANSTO, the Department of Defence, the CSIRO and the Commonwealth Department of Health. This levy should be weighted in accordance with the waste generated by each agency and the distance that waste is transported. The levy should capture the entire capital and recurrent cost of the measures proposed in Annexure ‘A’.
Further, the State Governments of Victoria, Queensland and Tasmania should also be levied for each truck movement carrying radioactive material that enters NSW. A similar levy should be applied to the Territory Government’s of the ACT and Northern Territory.
A levy applied using the mechanism of the fire service levy may also provide for other costs associated with the Commonwealth Governments proposal.
That said, any serious cost/benefit analysis would surely find that the operation of the reactor could not be justified in economic terms. If the Commonwealth chooses to provide justification for the existence of nuclear waste on other terms then it should be prepared (as it has done previously) to adopt a user-pay approach.
Terrorist Related Incidents
These incidents differ from normal hazardous materials events because the intent of the terrorist is to inflict mass damage to property and life. They involve the actual or potential release or activation of chemical, biological, nuclear, radiological, explosive or incendiary agents or devices. Fire Services will often be the first agency at the scene of a terrorist act and face a complex set of operational requirements including fire suppression, search and rescue, first aid, crowd control and site security, as well as those relating specifically to hazardous materials incident mitigation, decontamination and recovery. 1
(1 AFAC Best Practices Model for Hazardous Material Response)
US studies 2 have contemplated the use of anti-tank weaponry by terrorists to pierce the packaging and cause the intentional dispersal of nuclear waste. Estimates of clean up costs in the event of such an attack on nuclear waste undergoing transportation vary from US$500,000 to US$3 billion.
(2 NUCLEAR WASTE TRANSPORTATION SECURITY AND SAFETY ISSUES – The Risk of Terrorism and Sabotage Against Repository Shipments by Robert J. Halstead and James David Ballard State of Nevada
Agency for Nuclear Projects)
The FBEU is not aware of any domestic study into the likelihood of a terrorist attack on nuclear waste undergoing transportation nor has it been considered alongside the possibility of an accident in Chapter 7 of the Draft EIS. No consideration appears to have been given by the Commonwealth Government to the possibility of the packaging being intentionally pierced by malevolent act. This omission is consistent with the previous form of the Commonwealth.
The Commonwealth Government has refused to release to the State Government information about the potential for a terrorist attack on the Lucas Heights reactor. More recently the Commonwealth has suppressed vital sections of a report that outlined the likely consequences of an act of sabotage provoking radioactive release.
Given the heightened possibility of a terrorist related incident the FBEU believes that any assurance given by the Commonwealth in relation to the ability of the packaging to withstand normal accident impacts is unacceptably narrow in failing to consider the issue of terrorism and sabotage.
Moreover, in recent days, the Prime Minister has made public statements confirming the belief that Australia and its citizens are at risk from terrorist activities. The Prime Minister went further to state that the risk extends back for “a few years”.
It would appear to the Union that the Commonwealth Government has omitted to contemplate a scenario that departs from the domestic concerns related to transportation of nuclear waste.
In time, it may prove that this omission is of a crucial nature.
The principal author of this submission attended a public meeting held recently at Katoomba where with the NSW Minister for the Environment, the Hon. Bob Debus made the following observation.
“It is an extraordinary contradiction that we should establish the Blue Mountains area on the UNESCO’s register of World Heritage in one year, and then a few years later make it a place through which we engage in the permanent transportation of medium-level nuclear waste.”
This Union, representing professional firefighters tasked with protecting the citizens of NSW endorses the logic of the Minister’s statement and contends that any damage to significant environmental sites may be irrecoverable. At the very least, the release of a radiological substance will involve clean up costs of great magnitude. What that occurrence may mean to the people of the Blue Mountains, leaving alone its heritage listing, does not bear contemplation. Equally, professional firefighters understand that an environmental catastrophe is far more likely to occur in many more parts of Australia if the Commonwealth Government’s proposal is realised.
1. That the Commonwealth Government’s proposal to establish a National Repository for the storage of nuclear waste anywhere in Australia should not be supported.
2. That the professional firefighters of NSW supported by the entire membership of the UFU will actively oppose the construction of a nuclear waste dump within Australia’s borders.
3. That the people of Australia should support its professional firefighters in recognising that we have no capability in meeting the threat proposed by the Commonwealth Government.
4. That trade unions, community groups, political organisations and environmental groups should combine to ensure that no transportation of nuclear waste takes place.
In the interests of a full and proper investigation of the matters before the Standing Committee, the Union is prepared to make whatever resources it has available to the Inquiry. Accordingly, the Union’s executive members are available at short notice to address the Inquiry if that is the wish of the Standing Committee.