Response to FLAG

30 March 2017

Department of Industry, Innovation and Science crest

1.     Can the different phases of the project be clearly outlined, stating exactly what activities will happen and when?

Information about the different stages is already available on our website as well as in our information booklet.

Exact timelines for future phases are obviously dependent on progress in the current stage and thus may be subject to change.

2.     Since the project was announced , public consultation has been conducted privately, one-on-one, filtered through the Federal officials . Will there be any public forums where both sides of the debate can be openly presented?

This is untrue.

There have been a number of open public meetings held at Hawker and Quorn during the 120 day consultation  phase at which we were available to explain the project and answer questions from the public.

Subsequent to these the department is conducting its community consultation through a range of methods . This includes private one-on-one meetings if requested by the individual, but also through group meetings/presentations, public 'town hall' style presentations including Q&A sessions, discussions via Facebook , a webinar, ongoing publication of monthly newsletters, and not least through the Barndioota Consultative Committee (BCC) . The BCC comprises a range of stakeholders with differing views (including a FLAG re pre sentative ). This forum provides an opportunity for debate and discussion around a range of issues.

The recent webinar included  people  who do not  support  the  siting  of  the facility.

There is no bar to FLAG or any other group organising public debates around the project and we would encourage the  community  to  continue  to  engage in such discussions.

3.     The Yappala Community has entered into an Indigenous Protected Area (IPA) Agreement with the Federal Government to promote bio-diversity and cultural resource conservation. An element of the "Caring for Our Country" initiative supports indigenous communities to manage their land as an IPA. What consideration was given to the region's IPA status when Wallerberdina  was selected as the preferred  site?

Wallerberdina Station has not been selected as the preferred site.

The consideration of the nomination took into account the IPA status of the land referred to in your question. It also took into account the known registered heritage sites on and around Wallerberdina.

The department does not consider that the potential location of the facility somewhere within the over 6,000 ha of the nominated area would have any impact on the IPA status or activities at Yappala. It is important to note that IPAs promote a balance between conservation and other sustainable uses to deliver social, cultural and economic benefits for local Indigenous communities.

In any case, environmental approvals under the Environment Protection and Biodiversity Conservation Act 1999 must be obtained prior to the constriction of the facility, regardless of where it is ultimately located.

In terms of the cultural and heritage values associated with Wallerberdina the Government has committed to undertaking an Aboriginal Cultural Heritage Study before any further development or consideration of the site is taken.

4.       When will the cultural heritage assessment be undertaken for the site? What is the expected timeline?

The department is working with the Viliwarinha Yuras Aboriginal Corporation (VYAC} and the Adnyamathanha Traditional Lands Association (ATLA) in the form of a Working Group to progress the heritage assessment. The assessment is expected to be completed over the coming months.

5.     We understand that there will be studies undertaken to report on technical aspects of the site, such as, geology, hydro-geology and seismology. Have studies been done "on site" or have there only been desk-top studies and modelling?  Has there been any research conducted into historical data and anecdotal accounts? Has the Department taken into account earthquake data produced by the Hawker seismograph? Was there a cut-off point for earthquake severity and duration that was considered an acceptable  risk for   the  proposed site?  Will the public be able to see the results of these studies?

No studies have been conducted 'on site' as the department has made a commitment to undertake the Aboriginal Cultural Heritage Study before embarking on detailed site characterisation.

A comprehensive desktop Multi-Criteria Site Assessment (MCSA) was carried out on the site during the assessment of nominations received. Subsequent to that, further desktop studies have been conducted by Geoscience Australia {GA}.

These studies took into account the earthquake data available from the Hawker seismic station as well as the records kept by Geoscience Australia, as identified in the Site Selection Framework published on the website. The document also outlines a range of scores for various earthquake peak accelerations for a specified recurrence interval.

It should be noted that no assessment has been made with regard to 'acceptable risk' at the site selection stage, as risk is measured in terms of site specific conditions and the design of the facility. Further assessment of the site (site characterisation) and corresponding design will provide more detail.

Notwithstanding the above, GA monitors seismic data from more than 60 stations on the Australian National Seismograph Network. The area around Wallerberdina Station has seismic activity similar to Adelaide, Melbourne and Sydney, which is moderate by Australian standards. By international standards, the seismic risk of Wallerberdina Station is low. For example, the entire land area of Italy, Greece and Turkey have higher hazard levels than Wallerberdina Station.

Our initial understanding of the seismic record in the area suggests that a facility could be engineered safely to well beyond the tolerances that might be needed based on historical record. However, this will be confirmed through a detailed follow up study of the sites and the region's geology.

No facility will be proposed unless we are confident that seismic activity poses no material risk to human health or the environment.

6.     At the original Town Hall meetings we were told that the dump would create about 15 full time jobs at Wallerberdina. We now hear reports that a dump at Kimba would provide 30 full time jobs. How many full time jobs will be created at the dump site? Why is there such a difference in the number of jobs stated? How many of those jobs could be filled from the local community? Will any of the jobs associated with the dump require the applicant to live in the local community and, if applicable, relocate his family there?

The department has consistently stated that at least 15 full time jobs will be needed to operate the facility­ we have not used any other numbers to indicate  possible jobs.

We have also consistently stated that the Government will work with short-listed  communities to identify  plans to maximise local job and business opportunities including any training needs to support this. We expect that the majority of jobs will not require highly specialised skiffs, and could be drawn from the local community in most cases. Where they can't, this offers the prospect of bringing in new members to the community which can provide a further boost to the local economy.

The exact nature of potential roles and the extent to which those roles are based in the local community will be dependent on the site, as well as the safety and security requirements of the facility. These workers are likely to be based both on site, nearby to the site and in some limited cases, remote to the  site.

7.       How will the dump be secured from vandals and terrorists?

Security measures around any radioactive waste management facility will be designed to mitigate a range of threats based on advice from relevant government security agencies. While the terrorist threat in Australia persists, terrorists globally have shown no propensity for an attack on a facility of this nature.

Waste materials will be stored in multiple layers of concrete enclosures, synroc or in vitrified glass inside approved storage containers. These waste forms do not generate heat or pressure and are not combustible or explosive. Gaining access to the waste would be extremely difficult and this type of facility is unlikely to be a desirable terrorist target. The low-level waste is not itself inherently dangerous and would not be useful in terms of posing a credible risk to a community.

The intermediate-level radioactive materials even if somehow exposed would require highly specialised equipment to be utilised for more than a few minutes without seriously harming the handler. Any exposed materials, which would remain immobilised in glass, synroc or concrete, would not pose a material threat to health beyond a moderate radius well inside the facility boundaries. The facility is not considered to be of any real military value and would be highly unlikely to attract specific attack.

No facility will be proposed unless we are confident that it has the necessary protections and safeguards against all plausible threats.

8.     A survey result showing 65% community support for the project moving to phase 2 is quoted as the reason to proceed with the dump in our region. We have conducted our own survey showing a completely opposite result. You should have received a copy of our report by now. Can we please have a copy of the original report which provided the reason to proceed, showing the methodology, number of people contacted and analysis of the data?

A copy of the report that was prepared after the 120 community consultation process in 2016 is here (PDF 696KB, DOC 844KB).

Minister Frydenberg considered the findings of these reports and other information (such as public submissions) at the time, and made the decision to shortlist Wallerberdina Station for further consideration.

With regard to the FLAG Survey, it is disappointing to see the information sheet attached to the survey which demonstrated biases and included factual inaccuracies, such as stating 'the Government wants to bury lower­ level wastes [sic] in shallow tranches'.

This is clear misinformation as we have consistently stated that the low level waste will be disposed of in an above ground facility. Advice from experts is that this information sheet would have biased the responses and therefore negate the integrity of the data. In addition, having FLAG named at the top of the survey, and advertising the FLAG's Facebook group on the survey may increase the response rate from people who are sympathetic towards FLAG's cause, possibly creating a response bias.

The FLAG survey had a response rate of 32 per cent, which is not necessarily representative of the Barndioota community. Collecting information in conjunction with the South Australian Government's entirely separate process 'Know Nuclear- Discover, Discuss, Decide' may have confused people and led them to believe that they were responding to the proposal being considered in the South Australian process - again producing a bias in the results.

By comparison, the ORIMA Research (ORIMA) survey undertaken at the end of Phase 1 was conducted independently from the Government to ensure it produced robust results and there were  no biases.

The ORIMA survey found that 65 per cent of respondents wanted to continue to Phase 2 of the process to site a facility. This survey received 146 responses from the Barndioota area, with a response rate of 50 per cent. The survey sample was randomly selected from the adult population in the Barndioota area, in order to be statistically robust.

The ORIMA survey was not coupled with any information about the facility. Furthermore, ORIMA conducted  a pilot survey to test their methodology.  In the  pilot, they collected  feedback on the survey. Only 3  per cent of  those surveyed said the survey was biased, and 79 per cent provided positive feedback. This demonstrates the robustness of the  ORIMA  survey.

9.     We are concerned that money continues to be spent on this project given we are told that it will not be forced on an unwilling community. When will the community be asked to decide and how will the poll/survey be conducted? Will all members of the community have an opportunity to vote or will it be conducted by some form of random representative sample?

This activity will be conducted after the completion of the heritage and site assessments. The department will seek community feedback on the best way to measure commu;1ity sentiment and willingness to proceed through the Barndioota Consultative Committee (BCC0 and through more general community discussions.

10.   Current State Legislation prohibits the dumping of nuclear waste in SA. The verdict of the recent Citizens Jury, looking into high level waste disposal, was overwhelmingly against nuclear waste for SA. Is it still the case that only the local community within a 50 kilometre radius of the proposed site will have a vote on this matter, given the implications for the broader South Australian community?

The community sentiment survey undertaken in February 2016 included residents within a 50km radius of Wallerberdina Station, and the remaining area of the Flinders Ranges Council not already within this radius.  This reflected  the  concept that those closest to Wallerberdina  Station have the  strongest interest in the  potential siting of a  facility  there.

At the Barndioota Consultative Committee  meeting  on 9  February 2017, some  members  suggested  they would like to  revisit  what  constitutes 'community'  around  Wallerberdina  Station  ahead  of  the assessment  at  the  end of  Phase 2 (refer Question 9). This topic will be  revisited in a future  Barndioota Consultative Committee   meeting.

Currently the Government and department remains committed to consulting with those living , or with a strong interest in, the area defined above .

With respect to broader South Australian views, the Community Views  Report (November 2016) produced by the South Australian Government  indicates that there is considerable support for a facility that would manage, store and dispose Aust ralia' s radioactive waste in South  Australia.

Finally, we do not believe that there would be implications from the establishment of this facility for the broader South Australian community given the presence of over 80 radioactive waste storage sites currently in place around the State, and certainly no greater implications than for the broader New South Wales  community from the operation of a reactor and interim waste storage facility at Lucas Heights in Sydney over the last 50 years .

11.   Throughout  the information period until now, we have heard no mention of any downside  to  the project, no  risk analysis  for possible accidents, or a " worst case scenario" . The recent French delegation said they have a document of some 2000 pages, relating to emergency strategies. Accidents or incidents may occur either inside the facility or in transportation. Has a risk analysis plan been compiled and will it include appropriate specialised emergency training and equipment for local "first responders" such as FRC  employees, ambulance, SES and CFS volunteers? Would local "first responders" be required to help deal with incidents that occur inside the facility?  Would local hospitals need any specialised equipment or supplies in addition   to their normal requirements?  Will a copy of this plan be available for public scrutiny?

As part of the approvals process for the facility, a safety case must be developed in conjunction with the detailed design of the facility.

This safety case will capture the necessary risk analysis, including emergency response requirements, equipment and so forth. During the course of the project's development, a fully detailed approach to emergency management, including the number, location and nature of emergency services and first responders' will be developed based on international best practice .

The extent to which hospitals in the  locol area  would be  required  to carry specialist equipment  will be dependent on the proximity of the site, the capabilities of the hospital, and the like. Any safety management documentation will be required to be made available on ARPANSA' s website.

We would be delighted to sit down with FLAG and work through any risks or concerns you believe we have not identified with the facility.

12.    What water resource will be used, for example, for mixing concrete, if the construction was to proceed?

This cannot be determined until a site assessment has been completed. However, this information will be available to the community  prior to any final siting decision or community survey/vote.

We will not be taking water out of local water systems at the expense of the landowners/farmers or the environment.

13.    Has a Transport Assessment plan been composed  for the site and will it be available for public scrutiny?

This cannot be determined until a site assessment has been completed. Any transport of materials to or from the site will be required to meet ARPANSA and South Australian regulatory requirements.

14.    Are there any pre-requisites on which companies, their location and experience will be contracted? Where will workers stay during construction period?

The exact nature of the procurement process has not yet been determined and will be decided by the Government as part of the Detailed Business Case.

The types of companies who may be engaged to undertake the construction of this facility would be required to comply with the Australian Procurement and Construction Council guidelines. The decision on where the workers stay during the construction period is likely to be a matter for the contractor that is successful in the tender process.

The community surrounding the proposed site have expressed an interest in the opportunities that may be available for them to participate in the project.

The government is committed to ensuring that local content to the construction and operations of the facility is achieved. The design of trade packages as they are let to market is a key element in enabling local businesses to compete. Typically, trade packages are broken up into large elements which may make it unlikely that a local business could tender. By breaking trade packages into smaller components, smaller businesses are given the opportunity to tender alongside other  businesses.

For example, consideration could be given to early works for site clearing where a smaller excavation contractor could undertake the work. Similarly, rather than letting a contract for the construction of all buildings, smaller buildings could be tendered separately (such as guard post) to enable local builders to tender.

This element of the project will also be discussed at the BCC to ensure any opportunities available to the local community are maximised.

15.    In addition to the $10 million trust and $2 million 16/17 community benefit fund, please outline what other payments have been or will be offered to the community if the project proceeds?

The final scope and structure  of  any community benefits  package  will be  a matter  for further discussion  with the  host  community  as the  project evolves.

At this point no additional monies have been offered to the community. The Government will seek to provide any site that proceeds into the technical assessment phase up to $2 million funding per financial year until a final site is selected.

The community members who are represented on the BCC are also remunerated.

We note that the government has requested  the participation of the  Adnyamathanha  community to contribute to the Aboriginal heritage assessment. The community members and/or appropriate organisations will be remunerated for this work including any support work required during any technical assessment.