This is extremely stressful to a lot of people and we hope that common sense will Your concerns have been noted and understood. See prevail and our beautiful Flinders Ranges will remain free of any nuclear waste the general statement above. dangers. 7 Dave Sweeney Section 1 Introduction: – Australian Conservation Modification made. Line 9 - Given that the proposed national radioactive waste facility (facility) is Foundation expected to store intermediate level waste for a period of between 100-300 years 9 Dec 2016 it is important to more accurately reflect this length of time. Modification made. ACF suggests that line 9 is changed to read: store radioactive waste for up to ‘…to several hundreds of years….. Accepted Line 48 ACF suggests replacing the word with this better – ‘temporary’ ‘interim’ – reflects the extended periods of storage either currently happening or proposed both here and overseas. ARPANSA agrees; however, the requirement as it is Line 58/59 ACF maintains that ARPANSA should also actively be informed by and – formulated has its origin in the ARPANS Act. reflect international best practice in non-radiological theme areas, including community consultation and cultural protection, in its decision making. Section 2 Information Requested: – Agreed that the information should be detailed Line 98/99 that the safety case must be enough to allow – ‘comprehensive enough to take an informed decision. stakeholders to form a view’ on facility safety ACF maintains that this stage must include detailed design plans and not simply a conceptual approach. The Guide includes requirements on justification and Line 128/129 ACF maintains that to realise the available technique’ there – ‘best optimisation, which inter alia entails comparisons of needs to be a dedicated and public review of the range of management options for options. Australia’s radioactive waste inventory. This has been and remains a long – standing and reasonable civil society call. Covered to comply”. Line 144/45 ACF notes the requirement that any facility applicant outline plans “Capacity – for the final disposal of waste in storage and urges that this include detailed costings and a demonstrated financial capacity to meet these. There is a real risk of future cost-shifting in relation to radioactive waste management and this needs to be actively addressed.
This is extremely stressful to a lot of people and we hope that common sense will prevail and our beautiful Flinders Ranges will remain free of any nuclear waste dangers. Your concerns have been noted and understood. See the general statement above. 7 Dave Sweeney Australian Conservation Foundation 9 Dec 2016 Section 1 – Introduction: Line 9 - Given that the proposed national radioactive waste facility (facility) is expected to store intermediate level waste for a period of between 100-300 years it is important to more accurately reflect this length of time. ACF suggests that line 9 is changed to read: ‘…to store radioactive waste for up to several hundreds of years….. Line 48 – ACF suggests replacing the word ‘temporary’ with ‘interim’ – this better reflects the extended periods of storage either currently happening or proposed both here and overseas. Line 58/59 – ACF maintains that ARPANSA should also actively be informed by and reflect international best practice in non-radiological theme areas, including community consultation and cultural protection, in its decision making. Section 2 – Information Requested: Line 98/99 – that the safety case must be ‘comprehensive enough to allow stakeholders to form a view’ on facility safety ACF maintains that this stage must include detailed design plans and not simply a conceptual approach. Line 128/129 – ACF maintains that to realise the ‘best available technique’ there needs to be a dedicated and public review of the range of management options for Australia’s radioactive waste inventory. This has been and remains a long – standing and reasonable civil society call. Line 144/45 – ACF notes the requirement that any facility applicant outline plans for the final disposal of waste in storage and urges that this include detailed costings and a demonstrated financial capacity to meet these. There is a real risk of future cost-shifting in relation to radioactive waste management and this needs to be actively addressed. Modification made. Modification made. Accepted ARPANSA agrees; however, the requirement as it is formulated has its origin in the ARPANS Act. Agreed that the information should be detailed enough to take an informed decision. The Guide includes requirements on justification and optimisation, which inter alia entails comparisons of options. Covered “Capacity to comply”.
comments-response-nrwmf-regulatory-guide.docx