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Capital Works Construction Project

Long term Management of

Australia's Radioactive Waste

Australian Government Department of Industry

Initial Business Case (REVISED)

This document is a public release version of the Initial Business Case,

which was considered by the Australian Government in April 2014.

This document has been shortened from the original and includes the

Executive Summary, Project Description, Project Background and Project

Requirements. Sensitive information such as cost estimates have been

removed to avoid prejudicing a future approach to the market to construct

and operate a facility. Some figures have been updatedto reflect

information on radioactive waste holdings published since April 2014.

�ACOBS"SKM

• Australian Gm-ernment

Department of lndu•try

Table of Contents

INITIAL BUSINESS CASE MANAGEMENT OF AUSTRALIA'S

RADI OACTIVE WASTE

Executive Summary .......................................................................................................................................................... 3

Business I Project Need ............................................................. ................. ................................................... .................... 3

The Case for Action ........................................................................................................................................................... 4

Urgency of the req uirement .............................................................................................................................................. 4

Basis for the options development ................................................................ . . . . . . . . . . . ......................................................... 5

Analysis of Options ............................................................ ................................................................................................ S Recom mended Actions ............... ....................................................................................................................................... 7

2. Project Description ....................................................................................................................................................... 8 Business Need ................................................................................................................................................................... 8

Project Scope ............................. ............................................................... ...................................................................... .. 9

3. Project Background ..................................................................................................................................................... 10

Australia's radioactive waste inventory .................................. ............................................................................. ............. ll

Definitions .......................... ................................................................................................................................ ............. ll

Future radioactive waste arisings ..................................................................................................................................... l3

States and territories ....................................................................................................................................................... l9

Radioactive Waste- Future waste arisings . . . . . . . . . . . . . . . . . . ................................... ...................................................... ........... 20

Radioactive waste - Remaining storage capacity . . . . . ......................................................... . . . . . . . . . ........................... ............ 21

Sum mary- radioactive waste holdings in Australia .......................................................................................................... 23

The Com monwealth Legislative /Regulatory environment .......................................... .......................................... ........... 24

Project Assumptions ................... ..................................................................................................................................... 27

3. Project Requirements ................................................................................................................................................ 32

.JACOBS' SKM PAGE 2

INITIAL BUSINESS CASE � � Australian Government

Department of Industry

MANAGEM ENT OF AUSTRALIA'S

RADIOACT IVE WASTE

Executive Summary

Business I Project Need

• The Austra l ian nuclear sciences sector has a wel l-earned international reputation for the design of its

regulatory framework, the qual ity and relevance of its industry research and for its safety record. In

most respects the industry is regarded as performing at world class with the notable and essential

exception of a long term disposal sol ution for radioactive wastes.

• Based on current estimates, rad ioactive waste arisings wil l, i n certa in key sectors, exceed capacity within 3.5 years.

• Radioactive waste is currently stored at multiple sites around Australia under a wide variety

of governance, safety and security arrangements.

• All of Austral ia's cu rrent waste options are interim measures with no long term d isposal solutions i n place for Commonwealth wastes, which represent the majority of both legacy waste and foreseeable

future arisings of low a nd intermediate level radioactive waste. (Australia's nuclear sector does not

produce any high level waste.)

• Austral ia's legislation, pol icy, regulatory framework and international commitments require fu ll l ife

cycle management across the nuclear science industry, including effective long term management of

radioactive waste.

• Previous approvals granted by the nuclear safety regulator for the development of the sector,

including the operation of the OPAL reactor, have been conditional upon demonstrable progress

towards a long term, national waste management solution includ ing disposal.

• There is a sign ificant risk that without the establ ishment of a long-term national solution for

radioactive waste management, Austral ia's nuclear science i ndustry wil l either be forced to cease

operations or wi l l have sign ificant regulatory conditions im posed that wi l l stifle any further

development and adversely impact its ongoing economic viabil ity.

• In the Commonwealth (primarily ANSTO, ARPANSA and CSI RO), it is est imated that there are some

1,500 staff d i rectly i nvolved with the nuclear science industry with a sign ificantly greater number

involved in the broader supply chain, particularly associated with nuclear medicine (of which some

10,000 doses are d istributed weekly to hospitals).

• The purpose of this busi ness case is to consider options that wi l l al low Austral ia to address the

absence of a long term storage solution within its industry framework and thereby meet both

domestic obl igations and international comm itments with regard to ful l l ife-cycle management of

the nuclear science i ndustry. This wi l l enable the ongoing operation and further development of the

industry for the benefit of all Austra l ians.

• The threshold capabi l ity required for long term radioactive waste management in Austral ia is for

disposa l of a l l legacy low level waste and foreseeable future waste aris ings over the next 100 years,

and for storage a nd eventual disposal of a l l legacy I LW and for future aris ings over the next 100

years.

• Specifical ly, this in itial business case explores the current situation with respect to radioactive waste

production and management in Austra l ia and considers options that wil l meet Austral ia's long term

waste management needs with in current pol icy, regu latory and budgetary considerations.

JACOBS. SKM PAGE 3

INIT IAL BUSINESS CASE •• . Australian Government

Dopartmont or Industry

MANAG E M ENT OF AUSTRALIA'S

RADIOACTIVE WASTE

The Case for Action

• "Business as Usual" (BAU) is not compl iant with Austra l ian rad ioactive waste policy, international

conventions ratified by Australia, nor the intent of nuclear safety regu lations. Furthermore, the

predominant location of the waste prod uction and storage at Lucas Heights in southern Sydney lacks

an ongoing social l icence to indefinitely store waste.

• Action to address the long term management of radioactive waste wi l l remove a burden from future

generations who would otherwise be required to contend with it (despite them not having enjoyed

the benefits of the activities that generated that waste).

• Action to permanently manage radioactive waste wi l l support the continuity and development of

Australia's nuclear sciences sector, which leads the world in many aspects of materials R&D, and

nuclear medicine production and to the safety of Austral ians.

• BAU for radioactive waste management involves the continuation of a fundamenta l ly inadequate

solution, and must at least involve the development and del ivery of a series of i nterim or

contingency measures for the ad-hoc storage of low and i ntermediate level radioactive waste. A

BA U a pproach is inefficient, expensive and poses avoidable risks to the continued operations of the

nuclear sciences and nuclear medicine production a ctivities in Austral ia.

• The BAU situation is applyi ng accumulating pressure on the nuclear safety regulator (ARPANSA) to

"draw a l ine in the sand" and refuse future l icences which are not underpinned by permanent

disposal or consol idated storage pathways for waste a risings, which would mean interruption

/cessation of activities at ANSTO and elsewhere.

• I nterruption of ANSTO and related activities would have s ign ificant negative employment, i ndustry,

hea lth and R&D impl ications for Austra l ia which has a mature, prod uctive and valuable rad ioisotope

production and research industry based around activities at ANSTO (Lucas Heights).

• BAU is poorly su ited to respond to an unforeseen "discovery'' of radioactive waste, such as from the

discovery of a conta minated site h itherto not classified as radioactive or the loss of control over a

disused radioactive source.

• World's best practice as practised overseas continues to demonstrate the safety a nd efficiency of

centra l ised long term LLW and I LW management facil ities overseas.

• The amount of i ntermediate level radioactive waste ( I LW) due to return to Australia from historic

operation of the H I FAR reactor and that anticipated from current operation of the OPAL reactor and

other sources wil l be higher than in the past, requiri ng a more consistent and long term approach

than the short-lived arrangements of the past.

• Austral ian State & Territories' holdings of low and intermediate level waste are distributed across a

large number of sites, pending the establ ishment of a consistent, national response.

• Deta i led development and delivery of a national radioactive waste management facility would g ive

rise to various benefits to the Austral ian comm unity, by provision of economic benefits (ski l ls

development, employment, science a nd industrial research), health benefits and environmental

benefits, and strengthen Australia's international stan ding via continued leadersh ip of bi lateral and

multi lateral treaties.

Urgency of the requirement

• Under current arra ngements, the existing LLW and I LW storage at ANSTO wil l be full by 2017.

Contingency measures, such as the construction of an i nteri m I LW store for reprocessed waste

returning from France, have had to be i mplemented for some waste streams due to delays in

establ ishing the national fra mework. Further delays in the framework wi l l result in additional

�ACOBS. SKM PAGE 4

� � Australian Government

Department oC lndu•try

INITIAL BUSINESS CASE MANAGEM ENT OF AUSTRALIA'S

RADIOACTIVE WASTE

contingency measures at ANSTO to ensure waste storage capacity is not breached and the safety of

operations is preserved.

• Without completion of a national radioactive waste management fra mework this decade, the

imposition of onerous l icence conditions by ARPANSA or blanket withholding of future operating and

other development l icences is expected.

• Following decades of discussion of the topic, the public awareness of radioactive waste management

can enable a rational public assessment of benefits and costs to take place.

• There is broad pol itical support at the Com monwealth level for a national long term faci l ity to be

sited, constructed and operated for the storage of Austral ian rad ioactive waste.

• A legal basis for a volunteered s ite for a nuclea r waste d isposal I storage faci l ity is now in place via

the National Radioactive Waste Management Act (2012).

• A site has been volunteered for the location of a faci l ity and there are good prospects for others to

be offered under the terms of the N RWM Act.

Basis for the options development

• The options development was undertaken via engagement with a range of Commonwealth

stakeholders, includ ing all major participants in the nuclear sciences and holders of radioactive

waste. These included ANSTO, CSIRO, Defence, Department of Industry and the nuclear safety

regulatory, ARPANSA.

• As well as engagement with stakeholders, options were developed which took heed of previous

Austral ian practical experience, and relevant overseas p ractice.

• Options were assessed in terms of their Regulatory and pol icy "al ignment", Whole of l ife cost

(capital cost, o perating cost, risk cost) at the P50 level, and non-financia l benefits and opportunities

arising (economic, social, environmental).

Analysis of Options

• The options ana lysis developed a l ist of 15 facil ity-based and operational-based options (and sub

options) for long term management of radioactive waste including the Business As U sual scenario.

• A Multi Criteria ana lysis of these 15 options resulted in three (3) key options (p lus BAU) being taken

forward for more detai led risk assessment and economic/financial assessment in a Deta i led Business

Case.

• A cost benefit analysis was appl ied to these three options which resulted in Cost Benefit Ratios of

three project options, relative to the Base Case ( BAU).

The option analys is presented a sma l l number of potentia l solutions for Austral ia's long term

management of radioactive waste.

On the basis of a value for money assessment (non-financial outcomes achieved per budget cost) the

option to del iver a co-located LLW d isposa l and I LW storage faci l ity in Centra l Australia in accordance

with ARPANSA Guidel ines (Option 2a) achieved the highest score.

This option i s the superior alternative among a set of 14 potential sol utions (and the Business As Usual

or base case) in a value for money assessment. Despite an 'al l hazards' approach in the development

of cost estimates, this option presents a BCR of(whilst applying a range of conservatively high

assumptions about cost) and a superior value for money score (dollars spent per non-quantified

financial outcome) .

.JACOBS. SKM PAGE 5

.� � Australian Government


INITIAL BUSINESS CASE MANAG E M ENT OF AUSTRALIA'S

RADIOACTIVE WASTE

Two other options were also identified which outperformed alternatives at the multi-criteria analysis

stage and it is recommended that these are a lso investigated further in a Detai led Business Case.

These options have the potential to del iver a key part of the long term vision for radioactive waste

management in Austral ia. They al ign closely with Austra l ian government policy and support aspects of

international best practice. As the single preferred option from subsequent investigations is

i mplemented, it wi l l provide opportunities to Austra l ian industry to rise to international leadership of

radioactive waste sol utions, and develop key ski l ls in nuclear safety and management which are

otherwise in decl ine .

.JACOBS' SKM PAGE 6

IN ITIAL BUSINESS CASE � � Australian Government


MANAG E M ENT OF A USTRALIA'S

RADIOACTIVE WASTE

Recommended Actions

The recommended actions arising from this IBC are to prepare a Detailed Business Case and

accompanying documentation to achieve Second Stage Capital Project Approva l and proceed to

del ivery of the preferred option. In summary terms, this wi l l enta i l :

1) Further investigations, including a whole of l ife cost estimation and non-financial assessment for

the three shortl isted options as described above, to come to a single preferred option for further

design development, regulatory approval and ultimately, del ivery,

2) Determination of a short l ist of potential sites for the preferred faci l ity design in accordance with

the N RWM Act. If more than one potential site is identified, complete initial and then detai led

technical, socia l, financial and environmental due d i l igence of vol unteer sites to confirm the ir

suitability, to produce a final selection,

3) Preparation and execution of a detai led communications plan and stakeholder engagement

strategy,

4) Preparation of a detai led investigation of the socioeconomic benefits and costs of the preferred

option in view of proposed siting,

5) Assessment and information gathering necessary for Commonwea lth or State & Territory approva ls,

including:

o EPBC Approval

o ARPANSA siting, construction and operating l icences, including the development of an

approved safety case

o ASNO safeguards permit,

6) Deta i led assessment of the whole of l ife costs of the preferred option to P80 level of confidence in

view of proposed siting, engineering concept designs, and operational concept,

7) Development of a detailed risk assessment and mitigation strategy development,

8) Development of a deta i led assessment of risk costs to P80 level of confidence in view of proposed

siting and operational concept, and

9) Confirmation of the procurement model for del ivery which best suits the needs of the

Commonwealth .

..JACOBS' SKM PAGE 7

INITIAL BUSINESS CASE Jii.J. � Australian Government

Dopartmont or Indu•try


RADIOACTIVE WASTE

2. Project Description

Business Need

Radioactive waste is the only significant form of waste in Austra l ia which lacks a long term

management solution.

Over more than 80 years, a variety of industrial, medical, Defence and scientific research activities

have created a quantity of low and intermediate level radioactive waste in Austral ia. This waste is held

by both the Commonwealth and the States & Territories, under a variety of short-term, "interim"

storage arrangements across a number of formal sites and a larger number of informal sites. With the

continuation of valuable scientific and industria l/medica l activities involving rad ioactive materials,

radioactive waste wil l continue to be produced which wil l be added to these, and add itional future,

interim stores until a long term, national sol ution is implemented.

Australia's radioactive waste management policy req uires that all waste generated nationa l ly be

stored or d isposed of within Austral ia at suitably sited faci l ities after being categorised in accordance

with the national classification, consistent with internationa l best practice.

This pol icy is a l igned with the princi ples of a multilateral treaty ratified by the Austra l ian Government

with the International Atomic Energy Agency ( IAEA) for the Safety of Spent Fuel Management and

Radioactive Waste Management1 that "radioactive waste should, as far as is com patible with the

safety of the management of such material, be d isposed of in the State in which it was generated."

While there exists a range of regulatory and governance frameworks for radioactive waste

management in Austral ia, they remain essentially unfu lfi l led while there is no route for actual di sposal

or long term storage. In the meantime, Australia's producers of radioactive waste operate under an

increasingly fragile range of 'contingency measures' which delay, rather than address, the key policy

issue.

Despite the s ignificant industrial and scientific value of ongoing nuclear science in Austral ia, the long

term management of waste by-products from this activity is essential ly ad-hoc and places the known

and potentia l future benefits of this activity at risk. There is a possibil ity that ongoing operation and

development of the nuclear science sector, which prod uces a stream of vital medical and other

scientific benefits to society, may be interrupted unless the independent nuclear safety regulator,

ARPANSA, is satisfied that international best practice in nuclear safety, incl uding long-term radioactive

waste management, is being addressed.

This Initia l Business Case ( IBC) report has been developed in accordance with Depa rtment of Finance

Guidel ines for the Two Stage Capital Approval process. The I BC articulates the bus iness need and the

case for change. Additiona l ly, various asset and management solutions and approaches have been

explored and assessed to enable the identification and describe the preferred solution to the long

term management of Austra l ia's radioactive waste. Importantly, the preferred sol ution wi l l enable and

support the continued operation and future progress of the national nuclear science sector.

1 The Joint Convention was ratified by Australia in November 1998 and came into force in November 2003

.JACOBs· SKM PAGE 8



Project Scope


RADIOACTIVE WASTE

The sco pe of the project is to identify a preferred long-term management solution for Austra l ia's

radioactive waste which meets Austra l ia's radioactive waste management pol icy and its international

obligations. This initial business case presents a case for a ction, and a set of feasible options which

outperform the base case (business as usual) , for further deta i led development and examination in a

detai led business case.

�ACOBS' SKM PAGE 9

� � IN IT IAL BUSINESS CASE

Australian Government

Department or Industry

3. Project Background


RADIOACTIVE WASTE

The radioactive waste held in Austral ia is predom inantly a legacy of Com monwealth and State

research and industrial activity associated with radioactive sources stretching back decades. A

detailed account of industry development and corresponding policy development is presented in

Figure 1 (timeline of Australian nuclear industry and rad ioactive waste policy).

Key events in the development of Austra l ia's nuclear science industry (right) and associated pol icy

developments ( left) are summarised and presented in Figure 1, below.

Mount Walton East Intractable Waste Facility opens, receives WA LLW for disposal

Low level radloactivewaste at several Commonwealth sites taken to ANSTO and then Woomera, SA

Commonwealth terms of reference for National Rad Waste Repository drafted. 18 sites Investigated and Woomera SA preferred

Commonwealth plans for Long Uved ILW store and site study commences.

SA passes legislation bannl� Rad __ __, waste disposal in Its territory

Plans forWoomerallW abandoned _j Plans for ILW store abandoned

HIFARSpent Fuel dueto

I return from France

ANSTO due to run out of space forLLW, ILW atlucas

L Heights

OPAl spent reactor fuel due to return to Australia �

-f----,

1999

2005

2017

-( 2018

2028

....__ __ Commonwealth radium research commences

'----- HI FAR reactor operational

'-------- Production of nuclear medicines commences

ANSTO established '--------(replaces AAEC)

...----- ARPANSA Established ---..1

Australia ratifies IAEAJolnt Convention on Rad waste and spent reactor fuel management

CWth Radioactive Waste ,.------ Management bill passed

,.------- HI FAR reactor closed

OPAL(replacement) reactor operational at lucas Heights

National Radioactive Waste Management Act Passes

Interim waste Store (IWS) contingency storage approved for siting, construction by ARPANSA

Nuclear Medicine Production due to relocate to larger, ANM facility on site

Figure 1 Timetine of Nuclear Science activity and Radioactive Waste Policy 1920-2028 (Source: SKM, Various)

�ACOBS" SKM PAGE 10



RADIOACTIVE WAST E


Australia's radioactive waste inventory

Definitions

Radioactive waste is defined as 'rad ioactive material in gaseous, l iquid or solid form for which no

further use is foreseen, and which is control led as radioactive waste by a regulatory body'2• The

classification of radi oactive waste has been defined in international standards developed by the

Internationa l Atomic Energy Agency ( IAEA).3

Three general categories of radioactive waste are determ ined according to their (radio)activity content

and half-l ife (duration of activity) .4 These three categories are referred to as - Low Level Waste ( LLW),

Intermediate Level Waste ( I LW) and High Level Waste (HLW).

The Austral ian (and internationa l) regulations for hand l ing, transport, storage and disposal differ for

each classification. These regulations are set by ARPANSA in association with the IAEA. Disposal

options range from exemption from any controls (i.e. landfi l l disposal) to deep geologic disposal in the

case of H LW. The radioactive waste classification system and disposal options are i l lustrated in Figure

2, below.

HLW

---ILW_ ..... ;:....

intermediate level w�te ' (intermediate depth '

disposal) '

\

\ \ I

VSLW very sl1ort lived waste

\decay storage) VLLW 1 .&

\ very low level waste � IC:==��========��====�(�Ia�nd�f�ill�d�i s�po�s�a�l)==========

� (�� I '6&-' / ?Yo

' ...._ EW = exempt waste ,. � (?> � ..... ·��\?) - _(exeption I clearance)

_ - J:>.us� -----Half-life

Figure 2 Conceptualisation of radioactive waste classification system and disposal options (Source: SKM after ANSTO 2011)

As shown in Figure 2, Austral ia's radioa ctive waste holdings are categorised at either LLW or I LW.

2 International Atomic Energy Agency, Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management, IAEA, INFCIRC/546, 1997

3 International Atomic Energy Agency, Classification of Radioactive Waste, IAEA Safety Standard Series, No GSG-1, 2009

4 In addition to these general categories there are further categories "below" the Low Level Waste category: Very Low Level Waste and Exempt Waste which can be disposed of direct to landfill and Very Short Lived Waste which can be disposed of in landfill after a brief decay storage period .

.JACOBS' SKM PAGE 11

INITIAL BUSINESS CASE • Australian Government


RADIOACTIVE WASTE


There is not currently and nor has never been any high level waste in Australia and there is no

intention for this proposal to enable management of high level waste. Radioactive waste classified

below LLW is exempt from the need for long term storage/disposal at a specially approved faci l ity.

The categories are defined as fol lows:

Low level waste (LLW): contains l imited amounts of long-lived rad ionucl ides. In Austral ia's case the

majority of LLW which is presently being stored i s :

o Contaminated items from the production of radiopharmaceuti cals (Commonwealth ) and use

of radiopharmaceuticals (States)

o Lightly contaminated soil,

o Operational waste from the research reactors HI FAR and OPAL and some decommissioning

waste, and

o Lightly contaminated laboratory items such as paper, plastic and glassware

This classification covers a very wide range of radioactive waste, from waste that does not require

any shielding for handl ing or transportation up to a ctivity levels that req uire more robust

containment and isolation periods of up to a few h undred years. There are a range of disposal

options from s imple nea r-surface faci l ities to more complex engineered facil ities. LLW may include

short l ived radionuclides at h igher levels of activity concentration, and also long-lived rad ionucl ides,

but only at relatively low levels of activity concentration.

Intermediate level waste (ILW): contains increased q uantities of long-lived radionuclides and needs

an increase in the conta inment and isolation barriers compared to LLW. I LW waste currently held by

Austral ia and expected to be prod uced in the future includes:

o General wastes from radiopharmaceutical production,

o Higher activity operationa l waste from ANSTO, including irradiation targets, ion exchange

resins, a luminium pieces of fuel rods and control arms,

o Reprocessed spent fuel elements (SF E) from Austra l ian research reactors returning from

overseas in large, shielded containers for long term (SO year+) storage, and

o Disused radioactive sources formerly used in medical treatment and currently stored at

hosp ita ls.

Austral ia's current radioactive waste invento ry i s sum marised in Table 2 (below). I t demonstrates

that of the waste currently in interim storage in Austral ia, some 93% of the total (by volume) is held

by the Commonwealth. Of the LLW, 95% is held by the Commonwealth. This waste type represents

85% of the total volume of al l radioactive waste stored in Austra l ia (4,248.28 m3 of 4904.78 m3) .

Table 2 Low and Medium-level radioactive waste currently in interim storage in Australia

Waste Type Low Level Waste (m3) lntennediate Level Waste (m3)

Commonwealth ANSTO 1,936 451

ARPANSA 0.28 6.5

CSIRO 2,100# 4"

Defence 12 90

Subtotal C'wth Total; 4048.28 m3 551.5 m3

States 200m3 (estimated) 105 m3 (estimated)

Total 4,248.28m3 656.5 m3

(Commonwealth 95%, States 5%)) (Commonwealth 84%, States 16%)

Source: CSIRO, DRET6, ANSTd, Defence. '(unsegregated bulk waste) "CSIRO ILW is comprised of -200 small items Note: This table has been updated to reflect waste volume data as of October 2014.

6 http://www.ret.gov.au/resources/radioactive waste/radiation radioactive/amounts/Pages/amounts.aspx Downloaded

01/10/13



Department or lodu5try

MANAGEMENT OF AUST RALIA'S

RADIOACTIVE WASTE

All waste represented above in Table 2, both LLW and ILW, is stored in various interim or

contingency arrangements, with nothing stored at a terminal or permanent location or in a

permanent manner.

This legacy radioactive waste, which has been amassed over a period of some 80 years (and

particularly ove r the past SO years), has neither a regulatory endorsement nor a "social l icence" to

remain in its current location and manner of storage indefinitely, and hence an alternative solution

for its long term management is required.

Future radioactive waste arisings

While Tab le 2 p resents the radioactive waste currently in interim storage at Commonwealth and

State o perated faci l ities, there is additional radioa ctive waste which is due to be added to the

national inventory in coming months and years. These future waste arisings are both an inevitable

consequence of past activities which have not yet been "rea l ised" as waste (su ch as reprocessed

spent reactor fuel waste from the now closed HI FAR research reactor) and future, foreseeab le

industrial and research a ctivities (such as OPAL research reactor-related waste, nuclea r medicine

related waste and other industrial activities). These "future waste a ri sings" wil l have a substantial

impact on the vol ume of I LW held by Australian a uthorities, and a smal l to moderate impact on LLW

volumes. The calculated im pacts are described below.

Reprocessed Spent Fuel Elements from the HIFAR Reactor

Austra l ia does not possess the technical capabi l ity to reprocess spent research reactor fuel to a

level which is safe for long term storage. Austra l ian legislation also prohibits the establ ishment of

such a facil ity. As a result, Spent Fuel Elements (SFE ) from the Austral ian reactors are reprocessed

overseas under a variety of bi lateral commercial and legal agreements with overseas governments

which do possess the capabil ity.

A total of 2,28 1 SFE from the HI FAR reactor were sent to the US, UK or France for reprocessing

throughout its SO year operating l ife. Fuel used in HI FAR that came from the US was returned to the

US under a Foreign Resea rch Reactor Spent Nuclea r Fuel (FRR-SNF) "take back" progra m and wil l

not return to Austra l ia . Fuel used in HI FAR that came from Euro pe was sent to the UK and France

for reprocessing. The waste ari sing from the processing of that spent fuel is scheduled to return to

Austral ia in keeping with current international practice and wi l l be classified as I LW upon its return.

The waste from Europe is expected to return in two batches, initially from AREVA in France in late

201S and from Dounreay ( UK) in �2018-2020 (see Table 3).

7 Management of Radioactive Waste in Australia, ANSTO January 2011.

.JACOBS" SKM PAGE 13

INITIAL BUSINESS CASE �. � Australian Government

Dtpartment of Industry

MANAGEMENT OF AUSTRALIA'S

RADIOACTIVE WASTE

Table 3 Returning HIFAR Reprocessed Spent Fuel Elements (ILW)8

Foreseeable waste volumes arising (ILW) Timing of arrival

HIFAR SFE (From France) 65 m3, comprising: Late 2015 1 x TN-81 Cask (27m\ 1 x Shipping container ( 38m3)

HIFAR SFE (From UK) 65 m3 , comprising: 2018-2020 1 x TN-81 Cask (27m\ 1 x Shipping container (38m3)

Total HIFAR SFE 130 m3 of Intermediate Level Waste Late 2015

The return of the HI FAR elements from France in 2015 will mark the first occasion that spent reactor

fuel wil l be repatriated to Austral ia. This scheduled return will take place in accordance with bi lateral

treaties between Australia /UK and Austral ia/France and in accordance with the provisions of the

Joint Convention and the principle of waste minimisation- where useful elements of spent fuel are

recycled as far as possible during the reprocessing phase and the remaining wastes are then

returned to the country which benefitted from its origi nal use for eventual disposal.

When the HI FAR spent fuel was sent overseas to the AREVA facil ity (in 1999) i t was presumed that

the waste resulting from its reprocessing would enter permanent storage at a National Radioactive

Waste Management Facil ity (NRWMF)9 ( in Australia) upon its return. With the NRWMF as yet not

establ ished, ANSTO sought and gained approval for an interim facil ity at ANSTO to specifical ly store

the HI FAR returned waste. This facility is d ue to be completed in mid-2015 in t ime for the returned

waste to be received from France and then, in 2018-2020 from the UK.

Decommissioning of HIFAR Reactor and Structure

As wel l as receivi ng the returned waste, parts of the HI FAR reactor itself and the bui ld ing it was

housed in wil l also become radioactive waste when it is decommissioned in coming years. Although

HI FAR was safely closed in 2007, its core and much of its superstructure remains ra dioactive.

ANSTO has not yet appl ied to ARPANSA for a l icence to commence decommissioning the faci l ity,

due to the lack of a permanent solution to host the waste. It i s under care and maintenance at the

present time.

When HI FAR i s decommissioned, i t is estimated that it wil l give rise to some 500m3 of I LW and

500m3 of LLW, after categorisation and compaction of the waste.

8 The batches of reprocessed spent fuel will each return in a single TN-81 cask. This is a proprietary storage system for the containment of radioactive waste which is vitrified to reduce its radioactivity levels and its volume. TN-81 casks represent the state of the art with respect to reprocessed spent fuel storage are in use in various countries and their known handling characteristics (weight, dimensions, inspection regime) which provide a basis for design requirements for a permanent facility and for both operating and capital cost estimates

9 At the time that the HI FAR SFE were sent overseas for reD�ocessing, the termillOIQg)' fa( the long term radioactive waste taci ity was the Commonwea th Radioactive Waste Management Facility lCRWMFJ




IN IT IAL BUSINESS CASE

Table 4 HI FAR Decommissioning - related waste {ILW Waste)

HIFAR Decommissioning (ILW)

HIFAR Decommissioning (LLW)

Foreseeable waste volumes arising

Return of Reprocessed Spent Opal Fuel


RADIOACTIVE WASTE

Timing of arrival

Approx. 2024

Approx. 2024

The fue l cycle for the ANSTO OPAL research reactor at Lucas Heights wi l l operate under a s imi lar

arrangement to that of the H I FAR fuel, with its first batch of spent reactor fuel i nitia l ly returned to

the USA under the FRR-SNF "take-back" program (unti l 2016) and then subsequent shi pments to

the UK and/or Fra nce for reprocessing and return to Austra l ia . It is expected that the spent fuel wi l l

be sent in batches approximately once per decade (with spent rods accumulating in the OPAL

reactor pool i n the interim) and return ing as one TN-81 cask and one I SO shipping container each

decade for the life of the reactor ( l ikely 3-4 batches of spent fuel ) . To date, no spent fuel from OPAL

has yet been sent overseas for reprocess ing.

Table 5 OPAL Reprocessed Spent Fuel Elements {ILW Waste)

OPAL SFE (Batch 1)

OPAL SFE (Batch 2)

OPAL SFE (Batch 3)

OPAL SFE (Batch 4)

Total OPAL SFE

Foreseeable waste volumes arising (ILW)

65 m , comprising:

1 x TN-81 Cask (27m\ 1 x Shipping container (38m3)

65m3, comprising:

1 x TN-81 Cask (27m\ 1 x Shipping container (38m3) 65m3, comprising:


65 m3, comprising:


195 m3 1LW

Waste arising from general OPAL activities

Timing of arrival

Not returning

(remain in USA)

2028-2029

2038-2039 (est.)

2048-2049 (est.)

By 2059

I n addition to the foreseeable waste stream from the spent OPAL reactor fuel , the operation of the

reactor itself gives rise to a measura ble waste stream of I LW and LLW in both l iquid and sol id form

(as well as lower classes of waste which do not require specia l ised long term storage or d isposal

solutions) . This waste arises from three main activities, the production of radioisotopes for nuclear

medicine, the i rradiation of s i l icon a nd the irrad iation of samples for neutron activati on ana lysis

(noting the use of neutron beams gives rise to a negl igible amount of radioactive waste) .11

The OPAL wastes, which h ave been produced s ince operations com menced in 2007 and wi l l remain

for the foreseeable 50 year l ife of the reactor, are as follows (Table 6, below) :

11 Nuclear Safety Committee Report on the ANSTO application for a licence to operate a replacement research

reactor (OPAL). 2005 .




INITIAL BUSINESS CASE

Table 6 Waste from OPAL activities (ILW and LLW Waste) per annum

Foreseeable waste volumes arising (per annum)

ILW LLW

liquid Wastes

Solid Wastes 0.2 m3 18 m3

Resins 2 m3

Totals 0.2 m3 19 m3

Waste arising from production of radiopharmaceuticals (Nuclear Medicine)


RADIOACT IVE WASTE

Timing of arrival

Since 2007

Since 2007

Since 2007

Nuclear medicine i nvolves the appl ication of specific radioactive isotopes (known as

rad iopha rmaceuticals) d i rectly to hospital patients to faci l itate a variety of vital d iagnostic tests and

therapies. The most commonly applied rad iopharmaceutica l across the world, with some 10,000 doses

produced each week in Austra l ia, i s Technetium-99m (also known as 'metastable technetium-99).

Virtual ly al l of it is produced from the decay of its precursor element, Molybdenum-99 ("Mo-99") which

is produced in the OPAL reactor and adjacent production faci l ity at the ANSTO (Lucas Heights)

premises12. The diagram below (Figure 3) summarises the local supply chain for Technetiu m-99m,

commencing with reactor irrad iation of uran ium ta rgets in a reactor through processing to Mo-99 and

conversion/decay to Tc-99m and its administration to patients.

"Mo supply chain

23su targets

Reactor target

irradiation

99Mo processing

facility

99Mof99"'Tc generators

Generator manufacture

99Mo,l99mTc

; •

Hospitals, pharmacies

Figure 3 The Radiopharmaceutical Production Chain (Mo-99) Source: OECD Nuclear Energy Agency, 201113

The use of these radiopharmaceuticals conti nues to grow in Austral ia and across the developed a nd

developing world, and Austral ia is posed to play a major international role in the provision of radioactive

precursor isotopes (specifica l ly Mo-99) in the future.

12 Tc-99m, which is produced from the decay of Mo-99 has a radioactive half-life of 66 hours, enabling it to be tra nsported

throughout the country and overseas while sti l l effective as a medical diagnostic tool. Tc-99m produced via direct pathways

without Mo-99, such as in a cyclotron, has a much briefer ha lf-life (6 hrs) with far reduced utility for medical applications.

Source: US EPA Radionuclides Series I technetium. 13 The Supply of Medical Radioisotopes: The Path to Reliabi lity, Nuclear Energy Agency, OECD 2011


� � Austnillan Government


INITIAL BUS INESS CASE MANAGEMENT OF AUSTRALIA'S

RADIOACTIVE WASTE

As noted a bove, Australia's nuclear medicine production faci l ity, located i n Bui ld ing 54 at the AN STO

Lucas Heights campus, produces 10,000 doses of Mo-99 each week for Austral ian domestic use (with

l imited exports) and generates 5m3 of I LW and 11.5 m3 of LLW per annum. This facility is due to reach the

end of its technica l life in 2017. It will be replaced with a 3-4 times larger, but far more waste-efficient

facil ity, the ANSTO Nuclear Medicine (AN M) Facil ity, due to commence operations in 2016. The

improved waste-efficiency of the ANM faci lity is due to the corresponding development of a Synroc

waste management facil ity which wil l reduce the volume of l iquid rad ioactive waste substantial ly.

Table 7 ANSTO Nuclear Medicine Operations {ILW and LLW Waste) per annum

Foreseeable waste volumes arising (per annum)

854 Mo-99 Production

ANM Mo-99 Production

(from 2016, includes Synroc)

Synroc Facility Operations

Total arisings (2016 onward)

ILW LLW

11.45 m 3

10.3 m3

1.9 m3

12.2 m3

Source: ANSTO Note: these waste volumes are additional to the OPAL wastes listed in Table 6.

Other Commonwealth Departments- Defence

The Defence hold ings are 90m3 of I LW and 12.5 m3 of LLW.

Timing of arrival

To 2016 {legacy)

2016 onward

2016 onward

2016 onward

The Defen ce holdings of radioactive waste are increasing at a rate of only three to four 205 litre

drums of LLW per annum (0.6 to 0.8 m3) and are not expected to i ncrease beyond this for the

foreseeable future.

Table 8 Defence Radioactive Waste Holdings

Foreseeable waste volumes arising Timing of arrival

ILW LLW

90m3 legacy

12.5m3 legacy

0.6-0.8 m3 Per annum

Source: Depa rtment of Defence

..JACOBS" SKM PAGE 17


Department or lndu•try

IN ITIAL BUS INESS CASE MANAGEM ENT OF AUSTRALIA'S

RADIOACTIVE WASTE

Other Commonwealth Departments - CSIRO

The CSI RO radioactive waste inventory is the largest of any Commonwealth agency by volume. It

comprises predominantly Low Level Waste associated with uranium and mi neral sands processing

research u ndertaken in the 1950s and 1960s.

The bulk of CSI RO LLW holdings are located at a s ingle faci l ity on Defence land at Woomera, in some

10,000 drums (each 20S i itres in capacity) which are inspected annual ly by CSI RO and ARPANSA under

the terms of CSI ROs i nterim storage l icence. The CSI RO drums conta in unseparated radioactive

contaminated soil, original ly brought to the CSI RO /DSTO site at Fisherman's Bend in Port Melbourne

and then relocated to ANSTO in 1990 and final ly to Woomera in 1992. This waste, 90% of which is

classified as Low Level, is considered legacy waste and the site at Woomera i s not receivi ng additional

materials.

In addition to the LLW holdings, CSIRO has a num ber of laboratories around the country which store

smal l amounts of I LW aris ing from scientific testing and industry research14• These wastes include

contaminated laboratory consumables and sea led radioactive sources ( industrial equipment) which are

awaiting repatriation to their country I company of origin or for which a point of origin cannot be

determined.

The waste minimisation pri nciples at CSI RO have been appl ied successfu l ly to the laboratory-based I LW

whereby only very smal l amounts of material contin ue to accumulate. Waste min imisation and

categorisation of the LLW has not been actively pursued to date and there i s an expectation that the

LLW in storage at Woomera could be reduced substantial ly fol lowing mechanical or chemical separation

of rad ioactive elements from non-radioactive soi l and other non-hazardous materia ls.15

Table 9 CSIRO Radioactive Waste Holdings

Woomera CSIRO Interim Store

Other CSIRO Stores

Future Waste Arisings

Source: CSI RO

Foreseeable waste volumes arising Timing of arrival

ILW LLW

2100m3

4

Close to zero Close to zero

legacy

legacy

Per annum

15 Procedures for the reduction of the volume of CSIRO LLW at Woomera have been applied to other similar

Commonwealth stockpiles in the past, including those for the Department of Defence, achieving volume reductions

in excess of 90% .



Departmont of Industry

States and territories


RADIOACTIVE WASTE

I n addition to Commonwealth Agencies (ANSTO, CSI RO, Defence, and ARPANSA), each Austral ian State

and Territory also holds l egacy low and intermediate-level rad ioactive waste. The sources of legacy

waste are main ly associated with the delivery of medical services in those states16, and disused sealed

sources (such as teletherapy, industrial radiography, steri l isation services, survey a nd inspection

equipment).17

Future waste arisings are expected to come from the same or s imi lar sources as legacy wastes.

Most states and territories don't offer col lection or storage services for radioactive waste (from private

holders), and urge holders to return any sea led sources to thei r point of origin (typical ly overseas).

Queensland and Western Austral ia do receive sealed sources from private holders for storage and

disposal, respectively. Neither jurisdiction charges for storage, but charge for disposal services on a cost

recovery basis.

Each state and territory has its own regulatory framework for the management of radi oactive waste, (a l l

of which actual ly predate the Commonwealth regulator, ARPANSA itself). Although the Austra l ian

jurisdictions aren't regu lated directly by ARPANSA , the various State and Territory G overnments are

moving towards a uniform approach with respect to radioactive waste management under the National

Directory for Radiation Protection, ARPANSA 2012 (N DRP) . The N DRP provides an overall agreed

framework for radiation safety. The NRDRP was developed via ongoing consultation between ARPANSA

and State and Territory regulators via the Radiation Health Com mittee (RHC), itself establ ished under

the ARPANS Act (1998) .

Sustainability of current arrangements: States & Territories

The states operate their regulatory frameworks (including accreditation to possess, l icence to use or

operate, facilities licences, l icences to transport, etc.) on a fu l l cost recovery basis via a system of user

fees. These are u pdated as necessary as for other forms of prescri bed waste.

States' holdings of radioactive waste are far smaller than the Commonwealth's in volume terms (some

5% of LLW and 17% of I LW, as shown in Table 2) however as they are located in far more numerous

locations including private stores, many of them are undocumented I unknown to state or

Commonwealth regulators.

The lack of consolidated storage (apa rt from Qld) presents an operational risk for state regulators who

are faced with achieving uniform design and operating standards across a large number of state

sanctioned sites.

16 The nuclear-medicine-sourced wastes held by the states are generally long-lived intermediate level wastes

(sealed sources} previously used for radiotherapy of cancer patients and the calibration of nuclear medicine

equipment. The vast majority of radioactive material received by the states for nuclear medicine diagnosis and

treatment ( Mo-99} are managed via delay and decay methods and disposed of to landfill or trade waste streams.

17 As for the Commonwealth, radioactive wastes arising from state or territory based extractive activities (mineral

sands and mining} are not regarded as radioactive waste and are excluded from this analysis .


INITIAL BUS INESS CASE � � Australian Government


RADIOACTIVE WASTE

Department of Indu•try

There a number of instances overseas where disused sealed sources stored in s imi lar circumstances

have been abandoned or erroneously discarded as non-radioactive waste (become 'orphaned'), leading

to serious accidents i nvolving loss of l ife and significant economic cost. Such sources a lso present an

ongoing security concern.

At the present time there doesn't appear to be any concern about the capacity of states to continue to

manage foreseeable amounts of radioactive waste via delay and decay I interim storage.

However the largely unquantified problem of 'orphaned' sealed sources in the private domain cannot be

addressed comprehensively unti l a broader national solution to radioactive waste is progressed . Whi le

the states don't have capacity concerns with their kno wn waste they have l ittle confidence in their

abi l ity to receive and safely store orphaned sources via an amnesty or similar arrangement.

Radioactive Waste - Future waste arisings

The foreseeable picture for radioactive waste growth in the future is related to four principal sources:

• ongoing production of waste ( LLW and I LW) as a direct by-product of ANSTO operation of

the OPAL research reactor to produce Mo-99 (nuclear medicine) and other industrial

products

• recei pt of future wastes from the reprocessing of spent reactor fue l (a lready 'spent' i n

Austra l ia and others sti l l t o be used and yet t o be processed/returned)

• future waste associated with the decommission ing of the H I FAR research reactor

• importation of i ndustria l , scientific and defence equi pment as sealed sources which conta i n

radioactive content which has long-lived radioactivity a n d which i s not returnable to its point

of orig in .

Waste Minimisation

Al l of the agencies i nvolved in rad ioactive waste management, whether Commonwealth or State &

Territory, are actively engaged in the min imisation of current radioactive waste receipts by various

means, including:

• Accurate classification of radioactive waste to identify appropriate conta inment and storage

I d isposal o ptions,

• Applying "delay and decay" for short l ived liquid and solid wastes prior to disposal when they

are no longer classified as radioactive waste,

• Segregation and compaction of wastes and other physical means to minimise volumes,

• Return of sealed sources to their point of origin (overseas),

• Application of state of the art warehousing techniques to gain maximum use of existing

faci l ities, and

• Development and appl ication of world-leading waste processing technologies to i mmobi l ise

and condense wastes.18

1 s The development of the Synroc® waste processing technology at ANSTO over 30 years is a prime example of

world leading radioactive waste management technologies being developed and applied in Australia. Once

operational in 2017, the Synroc® facility (located adjacent to the ANM Mo-99 production centre) will reduce the

volumes of liquid waste arising from the production of radiopharmaceuticals by 30% and will reduce legacy liq uid

ILW by over 95% .

.JACOBS. SKM PAGE 20



INITIAL BUS INESS CASE MANAG EM ENT OF AUSTRALIA'S

RADIOACTIVE WASTE

I n sp ite of these efforts (and ongoing investments) to mi nimise waste volumes, there are sti l l significant

foreseeable i ncreases in waste volumes to 2050 (and beyond), particularly for waste classif ied as I LW, as

shown below in Figure 4 .

Figure 4 Foreseeable Waste Volumes to 2050 - LLW (LHS) and ILW (RHS)

8,000

7,000

6,000

5,000

4,000

3,000

2,000

1,000

• LLW (special)

• LLW (o�rations)

Lececv uw m3

• ll w (Special)

• ll W (operations)

Lqacy iLW m 3

Figure note: "operations-related" waste arisings are from regular, foreseeable nuclear science activities. "Special" relates to

one-off events such as H I FAR decommissioning or H I FAR I OPAL waste returns. Legacy refers to existing waste inventories from

activities prior to 2013. Natura l ly Occurring Radioactive Materials (NORM) as found in oil & gas or mineral sands development

are not classified as radioactive waste and are excluded from the radioactive waste inventory.

Unforeseeable waste

This foreseeable waste accumulation is based on a combination of long term trends i n waste

accumulation (net of min imisation activities) as well as scheduled returns of waste to Austral ia fol lowing

processing. Th is amount should be regarded as a conservative estimate, given it excludes unforeseen

radioactive waste arisi ngs, such as could occur following the d iscovery of an undocumented

contaminated site on Comm onwealth or State or Territory land.

The range of Commonwealth research and industrial activities associated with radioactive materials

dates back to the 1920s and involved dozens of sites across the country where rad ium, thorium and

other highly radioactive elements were extracted a nd refined, with sometimes little understanding of

the requirements for their long term safe management. There remains a reasonable l ikel ihood that in

the next 20 years new sign ificant vol umes of radiation-contaminated soils may be discovered and

present an urgent predicament for Commonwealth of State authorities. The current (business as usual)

management arrangements do not provide any form of contingency for such scenarios, and they have

not been factored into the a bove calculations of future waste arisings.

Radioactive waste - Remaining storage capacity

One of the d rivers for long term management of radioactive waste, aside from the regulatory

requirement for "long term storage and disposal" on nuclear safety grounds, is the pred icted shortage of

capacity of existing ( interim) storage for key agencies. Once this capacity is reached, these agencies may

not receive additional waste and must either cease waste producing activities or pursue further (interim)

waste management measures .


�. � Australian Government



RADIOACTIVE WASTE

There are over 100 l icenced radioactive waste storage faci l ities located around the country, a l l of which

have interi m or temporary status. (The only site l i cenced for the d isposal of (Western Austral ian)

radioactive waste is the Mount Walton East I ntractable Waste facil ity, located some 480km from

Perth) .19

Al l interim stores are classified as either "open" or "closed", with the open stores sti l l receiving

radioactive materials a nd the closed stores a l ready at their operati ng l im its. Storage faci l ities are also

designed, constructed and operated under ARPANSA-granted l icence terms to store either LLW or I LW,

as per ARPANSA Regulations.

The key agency which i s approaching the capacity l imits for i nterim storage for both LLW and I LW is

ANST0.20 As noted i n Table 6 and Table 7 (above) even after extensive technical and operational

measures to reduce its volume of sol id and l iquid wastes, ANSTO has foreseeable waste aris ings of 7.5

m3 of I LW and 32.2 m3 of LLW per annum.

The only open LLW store at ANSTO is Bui ld ing 59, which conta ins some 1,432 m3 of Low level rad ioactive

waste in 20S i itre drums and some 774 m3 in a number of ISO shi pping containers. 21 There is

approximately 140 m3 of remaining capacity in B59 which represents 3.0 years of remain ing capacity

based on foreseeable rates of LLW a ccum ulation at ANSTO (without special waste receipts such as H I FAR

decom missioning)

The only open I LW store at ANSTO is Bui ld ing 27, which also has an expected remain ing capacity of 3.0

years (26m3) based on normal operations (without special foreseeable waste such as HI FAR

decom missioning or the return of OPAL spent fuel in the future). These capacities a re l isted in the

fol lowi ng table:

Table 10 Remaining capacity of present interim radioactive waste storage (excluding unforeseen waste)

ANSTO LLW Store ( Building 59 - Drums)

ANSTO ILW S tore ( Building 27) CSIRO Stores

Defence S tores

State and T erritory Stores/\

Remaining Storage

Capacity (years)

3.5 years

3.0 years

>10 years

>10 years

>10 years

Source: ANSTO and other agencies correspondence

As shown in Table 10, among the producers and accumulators of radioactive waste, the capacity of

rem aining ( interim) storage is a key concern for ANSTO, making the true "do nothing" scenario

untenable whi lst mainta in ing OPAL and AN M operations which produce unavoidable streams of low and

intermediate level waste.

19 The Mount Walton East Intractable Waste Facility is restricted by State legislation to only receive radioactive

waste generated in Western Australia. There is no foreseeable limit on its capacity to handle WA radioactive waste.

2° CSIRO and Defence are currently not facing a near term limit on their capacity to manage foreseeable radioactive

waste storage requirements, nor are the States & Territories.

21 Source: ANSTO correspondence .


� � Australian Gm-ernmeot


INIT IAL BUSINESS CASE

Summary - radioactive waste holdings in Australia


RADIOACTIVE WASTE

The case for action underpinn ing this I BC includes the fol lowing known facts about radioactive waste i n

Austra l ia :

• Radioactive waste is an inevitable by-product of a range of vital medical, industrial, defence, scientific

processes, of which ANSTO is the primary agent. Solving the waste requ i rements of the nuclear

science sector wi l l resolve the largest threat to its ongoing productivity.

• There are no l i cenced, permanent faci l ities to store or dispose of this waste in Austra l ia22 and

current waste storage arrangements are not compl iant with Austral ian pol icy for the

management of rad ioactive waste or spent fuel .

• The Commonwealth holds a large majority of both low level and intermediate level waste

• Over the next 20 years, the foreseea ble LLW produced wi l l be a fraction of total legacy waste

a lready held in Austral ia .

• With ongoing waste minimisation schemes, there are few activities expected to give rise to

add itional low level waste in meaningful quantities, apart from decommissioning of the H IFAR

reactor at some future date (500m3) .

• I ntermediate level waste wil l continue to be generated via nuclear medicine production and the

compulsory return of reprocessed spent fuel elements (SFE) from HI FAR and OPAL for the

foreseeable future.

• Over the next 20 years, I LW received/produced wi l l exceed total legacy waste al ready held of

this type (by total volume), due to the return of reprocessed spent fuel.

• There is very little movement of radioactive waste holdings from outside the Commonwealth

(State a nd Territories) to Commonwealth responsi bi l ity (ANSTO).

• There is l ittle remaining storage capacity at AN STO for its foreseeable radioactive waste.

• The precise extent and composition of waste held outside the Commonwealth (by states or

private organisations) is unknown.

22 With the exception of the Mount Walton East intractable waste facility (IWF), established in 1988 in Western

Australia. This facility is restricted by State Legislation to only receive Low Level Waste from Western Australian

sources .




Department or lodu•try


RADIOACTIVE WASTE

Figure 5 Comparison of Legacy (past) and Foreseeable Rad Waste volumes (C'wth and States)

Arlslnas for the next 20years

61%

The Commonwealth Legislative /Regulatory environment

The key pieces of Comm onwealth legislation which govern nuclear faci l it ies' development and

operations are :

Australian Radiation Protection and Nuclear Safety {ARPANS} Act 1998; and

Australian Radiation Protection and Nuclear Safety Regulations 1999.

The objective of the ARPANS Act is to "protect the health and safety of people and to protect the

environ ment from the ha rmful effects of radiation."

The ARPANS Act grants sole powers to the CEO of ARPANSA to l icence activities relating to control led

faci l ities (either 'nuclear i nsta l lations'23 or 'prescribed radiation faci l it ies'24) . The activities in relation to

controlled faci l it ies which require a l icence are:

i . preparation o f a site for a control led facil ity,

i i . construction of a control led faci l ity,

i i i . possession or control of a control led facil ity,

iv. operation of a control led faci l ity, and

v. decom mission, abandon or d ispose of a faci l ity.

Each of these five development l icences is independent, and the CEO of ARPANSA may choose to l icence

site preparation but not construction of a control led faci l ity (or construction but not operation etc. ) u ntil

23 Nuclear Facilities are defined in the Act as (a) a nuclear reactor for research or production of nuclear materials

for industrial or medical use (including critical and sub-critical assemblies; (b) a plant for preparing or storing fuel

for use in a nuclear reactor as described in paragraph (a); (c) a nuclear waste storage or disposal facility with an

activity that is greater than the activity level prescribed by regulations made for the purposes of this section; or (d)

a facility for production of radioisotopes with an activity that is greater than the activity level prescribed by

regulations made for the purposes of this section.

24 A Prescribed Radiation Facility means a facility or installation that is prescribed by the regulations under Section 32 of the Act for the purposes of this definition .


Australian Gowrnmcot

D•partmont of Industry

INITIAl BUSINESS CASE

it is satisfied that the facil ity is fully compliant with the two pieces of legislation (above).

MANAGEMENT O F AUSTRALIA'S

RADIOACTIVE WASTE

As part of the overal l safety case for any nuclear faci l ity seeking a l icence of any type, the CEO of

ARPANSA must consider the operational safety arrangements which wil l apply and be convinced that

there is a net benefit to society arising from the granting of the l icence given the increased risks of

exposure to radioactivity. Key a mong the operational safety i ssues for consideration is the prospective

management of any rad ioactive waste (whether I LW or LLW or lesser categories of waste, in e ither sol id

or l iquid form) arising from the granting of the l icence.

In addition to admin istration of these two pieces of Commonwealth Legislation, ARPANSA a lso

administers Austral ia's rights a nd obl igations under a number of specific international treaties, with the

most relevant to radioactive waste storage being the IAEA Joint Convention on the Safety of Spent Fuel

Management and on the Safety of Radioactive Waste Management (the "Joint Convention") which was

ratified by Austral ia in August 2003.

The broad objectives of the Joint Convention are25:

• to achieve and maintain a h igh level of safety worldwide i n spent fuel and radioactive waste

management, through the enhancement of national measures and international cooperation,

• to ensure that during al l stages of spent fuel and radioactive waste ma nagement there are

effective defences against potential hazards, in such a way that the needs and aspirations of the

present generation are met without compromising the abi lity of future generations to meet

their needs and aspirations,

• and to prevent accidents with radiological consequences and to mitigate consequences should

they occu r during any stage of radioactive waste management.

The relevance of the Jo int Convention is described in a recent letter from ARPANSA, as fol lows:

"As part of the obligations under the Joint Convention, Australia, nationally, must act responsibly

with regard to its own radioactive waste. The three-year reporting cycle under the Joint

Convention has contributed to a better national understanding in Australia of the radioactive

waste management issue, considering the federal nature where each State and Territory is in

control of their own waste, and it has also contributed to a much improved inventory of

radioactive waste across all jurisdictions which is of importance for the construction and future

operations of the NRWMF. The NRWMF is part of Australia being nationally responsible. "

Source: Letter from CEO of ARPANSA, dated 17 January 2014.

Continued adherence to the Jo int Convention is in Austra l ia's national interest, as described by ARPANSA

as fol lows:

"Australia was an early and consistent supporter in the development of the Joint Convention.

Australia's support was based on: being a good international citizen; concern that poor practices

25 As described in the National Interest Analysis, Regulatory Impact Statement, 2002 .


INITIAL BUS INESS CASE




RADIOACTIVE WASTE

elsewhere may ultimately directly affect Australian citizens; the long term viability of Australia's

uranium industry that relies upon a responsible "whole of lifecycle" approach to nuclear

activities; and a growing awareness of security issues with nuclear material.

"The successful adoption of the Joint Convention involved working through a complex range of

issues including trans-border movement of material and implementation of international

reporting obligations. The broad adoption of the Joint Convention by nuclear nations has

dramatically reduced concerns internationally and international risks associated with

management of spent nuclear fuel and radioactive waste. Those significant nuclear countries

who have not become signatories to the Joint Convention are in a small and clearly identified

minority. It would not be in Australia's interests to be identified as one of these few countries.

Over the period s ince ratification of the Joint Convention, l icensing decisions made by ARPANSA have

requ ired increasing levels of evidence for progress towards a permanent and national approach to

radioactive waste management.

In the decision to grant an operating l icence for the OPAL reactor (2006) the then CEO of ARPANSA, Dr

John Loy referred for the need for certainty in the delivery of a sol ution for the storage and disposal of

radioactive waste,

" . . with regard to the (storage of radioactive waste) there would need to be substantial and

evident progress- such as the features of the design settled, siting criteria established and a

strategy and timetable in place for a site(S) that it was moving forward with clear paths to its

future establishment and I could be satisfied that a store WILL exist"26

I n its more recent decision to grant a siting l icence and a construction l icence for the I nterim Waste

Store for returning HI FAR SFE waste (November 2013) the CEO of ARPANSA noted,

"Maintained and tangible progress in realisation of the plans for the establishment of the

NRWMF remains a priority, for the system for radioactive waste management in Australia in

general, and for the operation of the IWS Facility as a temporary store in particula?7.

These statements, combined with the letter from ARPANSA referred to above demonstrate the ongoing

and increasi ngly specific ARPANSA requirement for a national, permanent approach to radioactive waste

management, and of the l inkage between a national, permanent approach and future l icences for

nuclear facilities a lready in stages of development.

26 Decision by the CEO of A RPANSA on Application by ANSTO for a licence to operate the opal reactor.

Statement of reasons 14 J uly 2006

27 Decision by the CEO of A RPANSA on Application by ANSTO to prepare a site for [and construct) the Interim

Waste Store (IWS) at Lucas Heights Science and Technology Centre . Statement of reasons 29 Novem ber 2013 .



Department or Indu•try


The National Radioactive Waste Management Act (2012)

MANAG E M ENT OF AUSTRAL IA'S

RADI OACTIVE WASTE

On 4 April 2012, the National Radioactive Waste Management Act 2012 (the Act) came i nto effect,

replacing the Commonwealth Radioactive Waste Management Act 2005. The Act establ ishes a legislative

framework for s iting a nd operating a faci l ity for on volunteered land. This approach accords with

international best practice. The objective of the National Radioactive Waste Management Act is to

ensure that radioactive waste generated, possessed or controlled by the Commonwealth, or a

Commonwealth entity is safely and securely managed .

The Act enables the min ister to consider voluntary nominations of land to host a radioactive waste

management facil ity from Aboriginal land councils in the Northern Territory under the land council

process or landowners in al l states and territories under the nationwide process. The Minister may then

declare the site as the location, procure the site and construct and operate a National Radioactive Waste

Management Facil ity. This legislation, which received broad support in its passage through both houses

of Parl iament, is regarded as the last required piece of enabling infrastructure required for the

establishment of a permanent radioactive waste management facil ity in Austral ia.

Project Assumptions

The project background presented above (Section 3) includes a number of working assum ptions, based

on extensive consultation with the Commonwealth Department of Industry, AN STO, ARPANSA, Defence

and other stakeholders.

These assumptions include the future operational characteristics of the nuclear faci l ities which give rise

to expected radioactive waste streams of LLW and ILW elements (principally the OPAL reactor and the

ANM, which is in construction). It also relates to the activities of other Commonwealth a nd State &

Territory agencies which wi l l give rise to the waste.

Other project assumptions include the location, composition and cond ition of legacy radioactive waste

held by the Commonwealth and States & Territories and the expectation that Commonwealth and State

& Territory agencies wi l l participate in a coordinated, national response to long term radioactive waste

ma nagement based on their own pol icy and risk management i nterests.

Another key assumption re lates to the efficacy of the National Radioactive Waste Management Act

(2012) to produce a volunteer site for the location of a national radioactive waste faci l ity which wi l l be

techn ical ly, demographically, fina ncia l ly and pol itically suitable for the task.

A s ingle volunteer site has been nominated for the location of a radioactive waste store and repository,

in the Northern Territory. It is poss ible that government intent to proceed with a Detai led Business Case

for long term radioactive waste management will spur further land holders to come forward with

additional sites for consideration .

The Cost Analysis of a lternative options conta ins a nu mber of assumptions, including a l ikely ( remote)

location for a bui lt faci l ity which appl ies Central Austral ia (NT) as an example remote site for the

purposes of establ ish i ng a rea l istic (conservative) locality factor for consideration of capita l costs. The

Cost plan a lso makes assumptions as to the avai labi l ity of various forms of special ised equipment in

reasonable lead times .




Table 11 Project Assumptions

INITIAL BUS INESS CASE MANAGEM ENT OF AUSTRALIA'S

RADIOACTIVE WASTE

Issue Project Assumption

Key Policy Assumptions • The long term radioactive waste management requirement wi l l only

address Austral ian radioactive waste (not i mported waste)

Radioactive Waste

Holdings and Creation

Site Availability

T echnical risk

Role of the Australian

Nuclear Medicine

(ANM) Facility

.JACOBS' SKM

• Only LLW and I LW (as defined above) wi l l be managed or require

management. No high l evel waste is proposed to be managed under the

terms of this pol icy.

• The current Austral ian pol icy for radioactive waste includes d isposal for

LLW.

• While the Austral ian regulatory framework notes a preference for the

ulti mate disposal of I LW, it a lso recognises that storage for periods of tens

of years is often necessary. At present, only storage is a viable option for

ILW ma nagement in Austra l ia since specific site requirements and options

for geological d isposal have not been confi rmed. These cond itions are

l ikely to remain economically uncerta in, pending national and

international research which is expected to conclude in coming decades

•

•

•

•

•

•

•

•

•

(30-50 years ) .

Radioactive waste holdings as described are accurate and complete for

Commonwealth Agencies, and state holdi ngs have not been under

estimated by more than 10%.

Waste minimisation pol icies, regulations and techniques are expected to

remain largely unchanged for the foreseeable future.

The OPAL research reactor wi l l continue to operate unti l at least 2057 .

The H I FAR reactor wi l l be decommissioned in 2024, g iving rise to 500m3 of

ILW and 500m3 of LLW (both compacted and shielded) .

Foreseeable waste arisings are relatively minor for al l agencies (<5m3 per

annum) apart from ANSTO.

Foreseeable I LW returns in the next 40 years (as reprocessed spent fue l )

wi l l be larger than the current known stock of ILW held in Austra l ia .

The N RWM Act (2012) wi l l provide a number of sites which wi l l be

suitable for consideration to locate a N RWMF.

ANSTO wi l l continue to occupy its present campus at Lucas Heights (NSW)

indefi nitely (beyond 2055) .

There i s avai lable space at the ANSTO Lucas Heights Campus for the

establ ishment of additional i nterim storage (contingency measures) if required.

• The site for a national radioactive waste ma nagement faci l ity is expected

to be in a remote part of Austral ia .

• The techn ical risk associated with the operation of a N RWMF is low, on

the bas is of many years' overseas experience with s imi lar LLW d isposal

and I LW storage facil ities and of many years successful operation at

ANSTO.

• The ANM wil l have a n important role in the rel iable provision of

radiopharmaceutica ls for del ivery to Austral ian hospitals and for export.

PAGE 28

�. � Australian Government


Issue

Timing

Cost estimates

�ACOBS' SKM

IN ITIAL BUSINESS CASE

Project Assumption

MANAGEM ENT OF A USTRALIA'S

RADIOACTIVE WASTE

• The ARPANSA regulatory approvals processes relevant to a national radioactive waste management facil ity are well establ ished and wil l proceed

according to rel iable t imeframes, given appropriate risk management is in

place.

• The capital cost estimates for the project options are based on delivery of given designs at a site in Central Austral ia. A specific site has not been

determined and hence the capital cost incorporates conservative assumptions

regard ing power connections (standalone power only) road connections and

site earthworks requirements (moderately uneven site).

PAGE 29

• INITIAL BUS INESS CASE

Australian Gm-ernment


Key Project Stakeholders


RADIOACTIVE WASTE

There are a number of stakeholder groups which have a d i rect interest in the safe and cost effective

long term management of Austral ia's radioactive waste. Their interests are driven by statutory

obl igations and responsibi l ities, operational imperatives and defence of the publ ic interest.

The fol lowing stakeholders were identified in relation to this project and have been consulted as part

of the I BC development process.

Table 12 Project Stakeholders

Department of

Industry

Australian

Radiation

Protection and

Nuclear Safety

Agency

(ARPANSA)

Australian

Nuclear Science

and Technology

Organisation

(ANSTO)

Nature of Stakeholders' Interest I Obligation

Departm ent with pol icy responsi bility for radioactive waste management, oversight of ANSTO's activities and com pliance with the ANSTO and ARPANS Acts.

Federal Government Agency charged with responsibility for protecting the health and safety of people and the environment from the effects of i onising and non-ionising radi ation, established under the ARPANS Act (1 998).

On behalf of the Commonwealth, ARPANSA regulatory services branch regulates the use of radiation sources, faci lities and nuclear i nstallations, including radioactive waste stores.

ARPANSA is Australia's representative on the safety committees of the I nternational Atomic Energy Agency (IAEA) and ensures that the terms of the Joint Convention on Rad oactive Waste are fulfil led.

Established by the by the Australian Nuclear Science and Technology Organisation Act 1 987,

an agency within the portfol io of the Commonwealth Minister for I ndustry.

ANSTO manages and operates a variety of infrastructure related to the OPAL nuclear reactor at Lucas Heights and associated research, educational and waste managem ent facilities.

ANSTO is the custodian of a substantial proportion of Australia's LLW at its Lucas Heights campus, and most of Australia's I LW, arising from activities at the HI FAR and OPAL reactors.

ANSTO is the proponent of the ANM facility which will provide nuclear medicine for domestic

.JACOBS' SKM

Engagement in the IBC process

Departmental representatives from the Radioactive Waste Managem ent I Resources Division have di rected the devel opment of this I BC and have partici pated in engagement with additional stakeholders (as below).

Senior ARPANSA management has been engaged throughout the I BC process to clarify its requi rements with respect to regulatory approval of facilities and nuclear installati ons and how options for long term radioactive waste management (including the base case arrangements) align with these requirements.

Senior ANSTO management has been engaged throughout the I BC process to clarify its current operations (base case), and its future requirements with respect to radioactive waste storage (both legacy waste and foreseeable future waste arisings).

I n support of the I BC development, ANSTO has shared historic cost i nformation related to radioactive waste management and outl ined the business case for the development of the Australian Nuclear Medicine facility and the associated Synroc production pl ant.

PAGE 30

� � INITIAL BUS INESS CASE



Department of

Finance

CSIRO

Department of

Defence

State and

Territory

Responsible

Authorities

Nature of Stakeholders' Interest I Obligation

application and export from 201 7.

ANSTO is Australia's leading agency for radioactive waste management technology (categorisation, compaction, inspection) and employs a majority of Australia's nuclear scientists.

The Department of Finance (Policy and Advice Branch) will consider the I BC and make a recommendation whether the I BC meets the i nformation standards consistent with the Government's Two Stage Capital

Works Approval Process for Australian

Government Construction Projects.

The Department of Finance (Budget Group) will consider the merits of the proposal and make a recommendation for further funding to develop the Detailed Business Case.

CSI RO hosts 1 0 radioactive waste stores, three of which are standalone licenced facilities and 7

of which are attached to laboratory facilities.

CSI RO is the custodian of some 50"/o of the bulk LLW in i nteri m storage on Defence-occupied Com monwealth land at Woomera and has an active interest i n the devel opment of additional disposal pathways for radioactive waste.

Defence currently occupies radioactive waste stores, which contain both LLW and I LW. The Department is actively involved in waste minimisation and is seeki ng to reduce its radioactive waste holdings.

Each state and territory has its own legislation pertai ning to radioactive waste management, i nd uding storage, dsposal and transport.Z8

Each state has a declared radioactive waste stockpile, including LLW and I LW (mainly held by Health Departments arising from nudear m edicine activities) as well as a num ber of sealed sources of unknown provenance which cannot be return to thei r point of origin.


RADIOACTIVE WASTE

Engagement in the IBC process

Senior representatives of the Policy and Advice Branch have been consulted to confirm the approach taken i n the I BC.

Consultation with the manager of CSIRO's radi oactive waste management program to confirm location and extent of legacy wastes and expected future waste arisi ngs, cost profile of current arrangements, as well as requirem ents for long term storage.

Consultation v.ith the manager of the Defence radioactive waste management program to confirm the location and extent of legacy wastes and expected future waste arisings, cost profil e of current arrangements, as well as requirements for long term storage.

Representatives of radiation safety agencies i n SA and Victoria have been consulted as part of the I BC devel opment process.

28 States and Territories are not bound by ARPANSA regulations, however there is an ongoing forum (via the Radioactive Health Committee) to move towards national un iformity in regulation and licensing .


� � Australian Govtrnmeot

O.partment of Indu•try

INITIAL BUSINESS CASE MANAGEMENT OF AUSTRALIA'S

RADIOACTIVE WASTE

3. Project Requirements

Statement of Requirements

The requirement for this project is to del iver a long term management solution for Austra l ia's

radioactive waste and address the key remain ing gap in Austral ia's n uclear industry

framework. The fol lowi ng requ i rements were determi ned via stakeholder consultation :

Table 13 Requirements for Long term management of Australia's radioactive waste

Requirement

Regulatory Compliance

Capacity (years)

Typology of radioactive

waste addressed

Whole of Life Cost

Alignment with

Government policy

Risks in delivery and

operation

Timing

Measurement I meaning

T he proposed solution complies with relevant Commonwealth legislation and

the Joint Convention as well as related ARPANSA regulatory guidance with

respect to management of radioactive waste and spent nuclear fuel. It is likely

to achieve regulatory approval for siting, construction and operations.

T he proposed option delivers a solution which provides capacity to address

both legacy low and Intermediate level radioactive wastes and foreseeable

(future) arisings for decades to come

The long term management solution provides a solution for both LLW and I LW

held in Australia

T he proposed solution has a minimal foreseeable whole of life cost (capital

cost, opportunity costs, operational cost, decommissioning cost, risk cost) in

net present terms,

The proposed solution supports and aligns with government policies across a

range of fields, including nuclear safety, Industry Policy, employment policy,

indigenous opportunity, tourism, environmental protection, health and

wellness policy, and education policy.

T he proposed solution poses no unacceptable (High or Extreme) risks in the

delivery phase or in the operational phase as per the risk matrix I assessment.

T he proposed solution is able to be delivered in a reasonable timeframe,

relative to the urgency of the requirement.

Whi le these criteria are not intended to be presented in priority order, the requirement for regulatory

com pl iance and approva l is regarded as a l itmus test for any proposed rad ioactive waste

storage/disposal option. As stated above, the proposed solution must gain approval in itself (as an

operational method or faci l ity) and must also provide sufficient confidence to the regulator that as

'enabling infrastructure" the solution add resses the wider ARPANSA I IAEA expectation of long term

radioactive waste management (storage and disposal) such that ongoing operations and expansion is

permissible i n the future. Without this regulatory condition being met, there are significant risks (some

of which are quantified as financial risk costs) that the regulator wil l withhold future development

l icences and the continued operation and growth of Austra l ia's nuclear industry itself may be put at

risk.

The ultimate requirement for a long term management solution for Austra l ia's radioactive waste would


Australian Gowrnment


INITIAL BUS INESS CASE MANAG E M ENT OF AUSTRALIA'S

RADIOACTIVE WASTE

therefore be compl iant with ARPANSA regu lations (and otherwise com pliant with other

Commonwealth and State Legislation), wou ld del iver a capacity which was long-lived (all of Austral ia's

known Com monwealth and State-based legacy waste plus several decades at least of foreseeable

waste arisings), addressed al l forms of radioactive waste for which landfi l l or decay/storage/landfill

was prohibited - i.e. Long l ived LLW and I LW; had a low whole of l ife cost, supported a range of

socioeconomic, environmental and health pol icies, was low risk to del iver and would be rapidly

deployable (withi n 5 yea rs) .

Identification of Options to Meet Requirements

Given the requirement stated above in Table 13, a l ist of 15 options and sub-options ( including

Business as Usual) was developed in consultation with stakeholders, which have the potential to

meet the criteria.

The options i nclude a base case or 'business as usual" option which provides the base case

aga inst which all project options are compared. The base case is essentia l ly the status quo,

without m ajor i nvestment in long term radioactive waste ma nagement. As shown be low, whi le

this option doesn't have a large upfront capital cost, it does not come without a capital cost and

it also carries a significant r isk cost l inked with ongoing activity across the sector.

These fifteen options were deve loped based on workshops and d iscussions with various

stakeholders, as well as observation of comparable activity undertaken overseas for long term

radioactive waste management.

Options aside from base case i nvolve a significant departure from business as usual, in a manner

designed to provide a long term sol ution to Austra l ia's radioactive waste requirements, both

past and future. These options may be descri bed as "operational" or "faci l ity-related".

Base Case

Business As usual response

to requirements

Operational

response to Requirements

Operational Options for Long Term Management

Facil ity - re lated

response to Requirements

Operational responses to meet the project requ i rements may theoretically include:

a. Enhanced waste min imisation practices via changes I im provements to existing (business as

usual) m in imisation procedures

b. I mproved space efficiency of existing storage faci l ities by minor redesign I refit of existing

warehouses, beyond business as usual

c. Substitution of rad ioactive sources and with other non-radioactive alternatives to min imise

the amount of rad ioactive waste produced (beyond business as usua l )

d . Transfer I export of legacy and future radioactive waste permanently overseas

e. Operational ly-based disposal of radioactive waste (non-faci l ity based options such as

disposa l at sea)

..JACOBS' SKM PAGE 33

INIT IAL BUSINESS CASE � � Australian Government

Dopartment of Industry


RADIOACTIVE WASTE

Cons ideration of these operational forms of response demonstrated that ill! of the above

methods and approaches are either a lready being applied (options a, b and c are being pursued

rigorously and are incorporated i nto the BAU case) or they not technica l ly or legal ly feasible to

be undertaken in Austra l ia (such as options d and e) .

As stated above (Waste Minimisation on page 20), procedures to reduce the volume of

radioactive waste to the min imum acceptable a re a l ready practiced widely by the key agencies

which are respons ib le for radioactive waste under business as usual .

The impetus to seek Two-Stage Capital Works Approval for long term management of

Austral ia's radioactive waste was based on the perspectives of ANSTO and ARPANSA that

current operational practices regarding waste minimisation of waste aris ings in Austra l ia were

a lready well integrated into the regulatory and framework at industry best practice.

Engagement with sta keholders has confirmed this view and as a result the operationa l means to

meani ngfu lly reduce waste arisings are very l imited and while they must continue as a suite of

practices, they do not in themselves present a viable option for long term ma nagement.

Facility-Based Options for Long Term Management

Due to the tightly regulated nature of the nuclear sciences sector, and of radioactive waste

ma nagement in particu lar (both at the State & Territory and Commonwealth levels) there are

relatively few facility options which are rea l istic for the Austral ian s ituation.

The options which were considered were based on the threshold project criteria to provide a

ma nagement solution for both I LW and LLW according to best international practice for a period

of several decades (with 100 years as a design guidel ine).

Variations on faci l ity options which were considered i ncluded:

Colocation of LLW disposal and I LW storage on a single site and LLW I I LW on

different sites

Highly engineered and sim ple design approaches

Single sites and multiple sites

Shorter term I smal ler volume stores versus larger I longer term stores

As noted above (Project Assumptions on page 27), the siting for a proposed facility (whether

LLW and I LW combined, or LLW on ly) has not yet been acquired, though the criteria for siting

are well establ ished and hence a reasonable prediction can be made about the location of a

faci l ity and its cost. Siting has not itself been considered as optional per se, beyond the

theoretical discussion of a single versus multi-site alternative facil ity-based solution.

A longer l ist of options were considered in this I n itial Business Case.

Shortlisted options

Of these 15 options and sub options, none of the operational options were found l i ke ly to meet

the project requirements. Three options (p lus Business as Usual) were superior to the others

considered, based on their MCA scores (Table 14, below).

JACOBS' SKM PAGE 34

� � Australian Gowrnment



RADIOACTIVE WASTE

Table 14 List of options to meet the criteria

Option

1} Business As Usual

("Do nothing")

Overall MCA score of

-1.2

Brief Description

Continue as at present without long term radioactive waste management

arrangements in place and operate via a series of interim storage measures for

both the Commonwealth and the States and Territories (via ARPANSA-approved

"contingency measu res").

Propose separate ILW stores to be delivered at ANSTO prior to each separate

delivery of OPAL Spent Fuel (to the design of the current IWS with a delivery cost

of $8M each), and a 1,000 m3 capacity LLW store to be constructed in 2016 and

each decade thereafter ($1M each) with associated operating expenses.

Receipt of processed spent fuel elements schedu led as noted above. Continue to

seek ARPANSA operating licences for current facilities (including ANM operating

licence, IWS operating licence).

Continue with waste minimisation strategies (delay and decay, separation and

classification, compaction, dil ution, return to origin).

Continuation of current storage arrangements at the State and Territory level.

Notable possibility that ARPANSA may intervene to prevent further contingency

arrangements as inappropriate and interrupt or halt operation of OPAL research

reactor and associated nuclear facilities.

Significant Risk Cost of this option related to the above as well as other

foreseeable events (See Risk Analysis).

2} Develop National Radioactive Waste Management Facility (NRWMF) - several sub options

2a) ILW+LLW

(engineered above

ground) legacy +

future 100 years

Overall MCA score

of 2.5

2b) LLW only

(engineered above

ground design )

legacy + future

100 years

Overall MCA score

of 1.2

Construct and operate a NRWMF with 100 years' capacity at a remote site which

accords with NRWM Act 2012 and ARPANSA I IAEA G uidance29 with sufficient

capacity to host both legacy and future I LW (long term storage) and LLW

(disposal).

Transportation of national legacy waste in the first full year of operation and then

campaign (bulk) deliveries thereafter to minimise transport costs and risk.

Design to incorporate above ground disposal (engineered containment) for LLW.

Based on El Cabril (Spanish) concept design developed by ENRESA in 2013 which

has been in operation in Spain for 10 years.


classification, compaction, dil ution, return to origin).

Construct NRW M F with 100 years capacity for both legacy and future LLW at

(remote) site in accordance with the NRWM Act 2012 and ARPANSA Guidance.

I LW to remain at ANSTO until policy and technological solution for permanent

disposal of ILW are determined. Construct LLW based on El Cabril design basis.

T ransportation of national legacy LLW in the first ful l year of operation and then

infrequent campaign (bulk) deliveries thereafter to minimise transport costs and

risk.

I LW storage to continue at ANSTO with foreseeable capital and operating costs as

for the I LW element of the BAU.

29 ARPASNA Guidance includes Licensing of Radioactive Waste Storage and Disposal Facilities (Version 2 March

2013) and Regulatory Guidance for Radioactive Waste Facilities: Near Surface Disposal Facilities; and Storage

Facilities (December 2006)

JACOBS" SKM PAGE 35



Option

2c) LLW only

(trench design )

legacy + future

100 years

Overall MCA Score

of 1.1

�ACOBS' SKM

INITIAl BUSINESS CASE MANAGEM ENT OF AUSTRALIA'S

RADIOACTIVE WASTE

Brief Description


classification, compaction, dilution, return to origin).

Construct NRW M F with 100 years' capacity for both legacy and future LLW at

(remote) site in accordance with the NRWM Act 2012 and ARPANSA Guidance.

ILW to remain at ANSTO until technological solution and policy for permanent

disposal determined. Construct LLW disposal without capacity for future retrieval

in the futu re (below ground).

T ranspo rtation of national legacy LLW in the first full year of operation and then

infrequent campaign( bulk) deliveries thereafter to minimise transport costs and

risk.

ILW storage to continue at ANSTO with foreseeable capital and operating costs as

for the ILW element of the BAU.


classification, compaction, dilution, return to origin).

Some risk cost associated with this option.

PAGE 36

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