Jim Green - September, 1998
|A longer version of this document is available by ringing the Senate Economics References Committee on (02) 6277 3740 and asking for Volume Four of the submissions to the Senate Nuclear Reactor Inquiry. The longer version of this document adds more detail on the above topics and addresses many other issues. It also includes references to the supporting scientific literature.|
"(It is an) unfortunate state of affairs that dear old ANSTO, which lives off taxpayer's money, is feeding us all this propaganda and very little objective information. I thought governmental agencies are there to serve the public - not just to perpetuate themselves."
On March 29, 1998, ABC Radio National's "Background Briefing" dealt with the proposal to build a new nuclear reactor at Lucas Heights. Journalist Bronwyn Adcock said the federal government's strategy is to "deliberately overstate" the medical benefits of a new reactor. A "senior government source" made the following comments during his interview with Ms. Adcock: "The government decided to push the whole health line, and that included appealing to the emotion of people - the loss of life, the loss of children's lives .... So it was reduced to one point, and an emotional one at that. They never tried to argue the science of it, the rationality of it."
That the government pushes the medical arguments extremely heavily is beyond doubt. For example the first words of the press release announcing the reactor decision, from Mr. Peter McGauran, then federal Science Minister, began with these words: "The construction of a replacement research reactor at Lucas Heights will build on Australia's life-saving nuclear medicine capabilities." Mr. McGauran has made many other comments on the alleged need for a reactor to produce medical isotopes, most of them inaccurate and/or misleading (as discussed later). On the day of the reactor announcement, Mr. McGauran spoke in Parliament about using radioisotopes to save the lives of children with cancer. Senator Ellison did precisely the same thing the following day. Ms. Danna Vale, federal member for Hughes (the federal electorate which includes Lucas Heights), has made a number of dubious claims in relation to medical isotope supply (as discussed later).
The senior government source, interviewed on ABC Radio, discussed the government's secrecy: "The government decided to starve the opponents of oxygen, so that they (the government) could dictate the manner of the debate that would follow the announcement. Because they couldn't win it on rational grounds .... they decided, right, we'll play the game and in the lead up to the announcement catch them totally unawares, catch them completely off-guard and starve them of oxygen until then. No leaks, don't write letters arguing the point, just keep them in the dark completely."
Mr. Peter McGauran was asked by the ABC: "Did the government have a particular strategy to try and quell public debate on the new reactor?" Mr. McGauran responded thus: "We certainly believed that those who inquired of us for information should be given as much detail as was available to us." Mr. McGauran also said: "And in all of this ANSTO has a very comprehensive local community consultation process. Easy access to ANSTO. Any information sought is supplied ...." These are extraordinary claims, to say the least. The longer version of this document lists dozens of questions which ANSTO and the government refuse to answer.
These comments refer to a document released by Danna Vale, federal member for Hughes. Ms. Vale was asked to respond to my critique of her document, but declined to do so.
Ms. Vale claims that HIFAR has delivered "enormous" benefits for the environment, and that the construction of a replacement reactor at Lucas Heights will bring "substantive" environmental benefits. However very little of ANSTO's work has a positive environmental impact. Much of ANSTO's so-called environmental work involves the use of radioisotopes to monitor environmental pollution; a necessary task but not to be confused with improving the environment. Most of ANSTO's so-called environmental work uses i) radioisotopes (most or all of which can be imported or produced using accelerators) and/or ii) ANSTO's non-reactor instruments (Van de Graaff accelerator, Secondary Ion Mass Spectrometer, Australian National Tandem Accelerator for Applied Research, computers). On the other side of the equation, HIFAR has a negative environmental impact through the radioactive waste legacy, and also through routine gaseous and liquid radioactive emissions. ANSTO's own data reveals that annual production of intermediate-level liquid waste in the year 2025 will be 12 times 1993 production. This waste contains uranium and mixed fission products. In 1989 it was identified as having potential for off-site consequences in the event of an accident (e.g. a seismic event, or a major fire). In 1993, the government's Safety Review Committee noted continuing delays in the project to solidify this waste, and it noted that resources had not been applied consistently to resolve technical problems in a timely manner. In the 1996-97 Annual Report of the Safety Review Committee, the Committee said progress with solidification was unacceptably slow. In sum, the environmental balance-sheet is negative and will worsen with a new reactor.
Ms. Vale claims that "The existing reactor (HIFAR) has operated safely for almost 40 years since it was commissioned in 1958." In fact there have been many incidents and accidents at Lucas Heights:
Ms. Vale claims that "Over 50% of total (nuclear medicine) procedures are for life threatening reasons." However the vast majority (98-99%) of nuclear medicine procedures are diagnostic not therapeutic. Nuclear medicine is used far less frequently than other diagnostic imaging technologies such x-radiology, ultrasound, and computerised tomography. All of the radioisotopes with a more-or-less secure niche in nuclear medicine, and literally dozens of others besides, will still be available without a reactor in Australia - either by producing them in cyclotrons or importing them. Even ANSTO concedes that the "cutting edge" of nuclear medicine involves the use of cyclotron-produced radioisotopes. ANSTO also concedes that "many" radioisotopes can be imported.
Ms. Vale says that "Put simply, lives would be lost without a reliable source of radioisotopes." There would be very little if any suffering, let alone deaths, in the absence of a reactor in Australia, for the reasons mentioned above. If the federal government is serious about saving lives and preventing unnecessary suffering, then it would be far preferable to use the $300 million for preventive medicine and public health programs. In the science journal Search, Professor Barry Allen, former Chief Research Scientist at ANSTO, and now Professor of Pharmacy at Sydney University and Head of Biomedical Physics Research at the St. George Cancer Care Centre, says "Certainly the $300 million new reactor will have little impact on cancer prognosis, the major killer of Australians today."
Parroting a claim made by ANSTO, Ms. Vale claims that "It is possible to import many radioisotopes but, on average, every third shipment is delayed by at least 24 hours." However the South African Atomic Energy Commission - one of ANSTO's main overseas suppliers - claims that only 1 in 200 of its overseas shipments is delayed. I have written to ANSTO seven times seeking evidence in support of the above claim, but ANSTO does not respond. If ANSTO does have any evidence to support its claim, surely it would be prepared to release this evidence.
Ms. Vale claims that "The work carried out at the National Medical Cyclotron complements but cannot substitute the production of radioisotopes from Lucas Heights." In time, cyclotrons may be able to produce technetium-99m (Tc-99m), used in about 70% of nuclear medicine procedures. The second and third most commonly-used radioisotopes, thallium-201 and gallium-67, are produced in cyclotrons. As ANSTO says: "After Tc-99m, a series of cyclotron-produced radioisotopes, such as thallium-201, gallium-67, indium-111 and iodine-123, are the next most popular." Cyclotron-produced radioisotopes - such as iodine-123 and 18F-fluorodeoxyglucose (FDG) - can substitute for Tc-99m for a number of clinical applications.
Ms. Vale claims that "Australia has some 180 nuclear medicine centres. If they were reliant on overseas stocks, they would be on the end of very long supply lines from North America, South Africa and Europe. This would be especially critical for the most frequently used radiopharmaceutical Tc-99m (technetium), which has a half life of just six hours." In the past 5-10 years, a glut has emerged in the international radiopharmaceutical industry. The major producers have the production capacity to supply world demand many times over. Not all of the supply lines from overseas suppliers are "very long", and in any case more proximate suppliers can be found if necessary. The comment about the 6-hour half life of Tc-99m is misleading - an "unnecessary and public blunder" in the words of a former ANSTO employee. Tc-99m is drawn from a parent radioisotope, molybdenum-99 (Mo-99), which has a much longer half life (66 hours) and is widely transported around the world. Over 50% of all nuclear medicine procedures all over the world use Tc-99m drawn from imported Mo-99. Advanced industrial countries such as the UK and Japan are completely reliant on imported Mo-99/Tc-99m. Amersham supplies Mo-99 to Australia every week. During HIFAR shut-downs, all of Australia's Tc-99m is drawn from imported Mo-99.
In a letter to me (12 August, 1996) Mr. McGauran said: "Although the Research Reactor Review recommended that a decision on a new reactor be made 'in about five years time', it did not recommend that a new inquiry be undertaken." This is not true. The Research Reactor Review (p.4) stated unequivocally that "if, at some later stage, a new reactor is envisaged, it should be assessed by a new panel possibly operating within the Environmental Protection (Impact of Proposals) Act 1974". Moreover the Research Reactor Review clearly had in mind something more substantial than the Environmental Impact Assessment process currently underway.
Mr. McGauran said in Parliament (6-3-97) that "During this year more than 260 000 Australians will have a nuclear medicine procedure. ...... As a result of these procedures, some 35 spent fuel rods are generated by the Lucas Heights research reactor every year." This is incorrect. Only a small percentage of the spent fuel rods stored at Lucas Heights could be attributed to radioisotope production. Certainly a large majority of the low and intermediate-level waste stored at Lucas Heights is generated through radioisotope production and processing - but is that not a compelling reason to be pursuing alternatives to domestic reactor radioisotope production all the more vigorously?
When discussing nuclear medicine and radioisotope production, Mr. McGauran said in Parliament (5-3-97) that "So many thousands of Australians owe their lives to the research carried out at ANSTO." Some patients undergoing therapeutic nuclear medicine procedures may owe their lives to nuclear medicine. However therapeutic nuclear medicine accounts for just 1-2% of all nuclear medicine procedures. Only the tiniest fraction of diagnostic procedures (which account for 98-99% of all nuclear medicine) would improve patient management and outcome to the extent that it could justifiably be said that their lives were saved by nuclear imaging. Indeed a nuclear medicine professional, when quizzed by the Research Reactor Review panel, acknowledged that it would be difficult to demonstrate decreased mortality due to nuclear medicine. Similarly, Dr. Khafagi, an Australian nuclear medicine specialist and a member of the ANSTO Board, acknowledges in the journal ANZ Nuclear Medicine that "thorough evaluation of the only meaningful end-point - patient outcome - is scanty."
Mr. McGauran said in Parliament (5-3-97) that ANSTO has annual radioisotope sales to South East Asia of $700 000 and that the market is estimated to be $25 million annually and growing at more than 10% annually. However ANSTO supplies just 2.8% of the regional market (using the above figures). The situation in the region is that 10 countries operate research reactors for radioisotope production, and there is little scope for ANSTO to supply those markets. Some regional countries are modest radioisotope exporters (e.g. Indonesia) or will be in the near future (e.g. South Korea). In addition, the major global radiopharmaceutical companies have invested tens of millions of dollars in new or refurbished production facilities in the past five years. These companies - in particular Nordion, Mallinckrodt, Amersham, and the South African Atomic Energy Corporation - supply over 90% of the world market. They are operating in an industry with a large excess production capacity, and are likely to aggressively seek out and compete for new markets. Indeed these companies already supply markets in the Asia Pacific.
A crucial debate concerns the production of technetium-99m (Tc-99m) which is used in about 70% of nuclear medicine procedures) using particle accelerators (especially cyclotrons). ANSTO claims this is not an option, and quotes from the University of California Chemistry and Agriculture Program (UCCAP) internet site to "prove" the point. The quote, which is printed twice in ANSTO's Background Information document, appears to suggest that accelerator production of Tc-99m is not a viable option. However a visit to the UCCAP internet site reveals that the second of two paragraphs on this topic reads as follows (my emphasis):
"Particle accelerators have broad scientific applications and play an important role in providing a broad spectrum of isotopes for medicine and research. Accelerator technology has evolved rapidly over the last decade and produced a new generation of machines capable of operating with high reliability, multiple beams allowing for multiple targets, and high intensities. This new accelerator capability may allow for new methods to be developed for the large-scale production of radioisotopes."Further investigation reveals that both paragraphs were originally printed in a 1993 article by Dr. Manuel Lagunas-Solar, who is Chief of UCCAP and the world's leading researcher into cyclotron production of Tc-99m. The 1993 article concludes with the words that "The feasibility of producing technetium-99m in large Curie quantities (using accelerators) seems firmly established."
In short, ANSTO's selective quoting does not accurately reflect the UCCAP internet site, nor the 1993 article, nor the well-known views of Dr. Lagunas-Solar himself. Dr. Lagunas-Solar has written to the Australian Prime Minister on this matter, saying that: "It is my understanding that my work has been reviewed by ANSTO, without the benefit of my direct participation, and clearly using outdated and/or incomplete information. ANSTO also provided statements to Parliament based on information (also out of date) available through our internet site. Based upon a general analysis of ANSTO's review, I strongly feel that it does not provide an objective and balanced review of the actual status and/or the conclusions of our work."
In a Sydney Morning Herald article by Paul Cleary (24 September), former science minister Mr. Peter McGauran is quoted as saying that the UCCAP quote is included in ANSTO's material "as an interesting footnote" indicating that Dr. Lagunas-Solar has changed his mind on the cyclotron technique. Dr. Lagunas-Solar has done no such thing! The facts of the matter are that Dr. Lagunas-Solar's recent research papers show that significant progress has been made in relation to all of the important parameters - yield, imaging quality, purity, and specific activity of cyclotron-produced Tc-99m.
ANSTO (1997) says "No research reactor has ever adversely impacted its community." Ms. Danna Vale MP has parroted this claim. However, the nuclear industry acknowledges that there have been over a dozen serious research reactor accidents around the world, at least three of which resulted in loss of life (Yugoslavia 1958, USA 1961, Argentina 1983). According to a 1993 article in the Bulletin of the International Atomic Energy Agency, many research reactor operators find themselves in a "crisis situation" because of waste management problems. Research reactors can be - and have been - used in support of covert nuclear weapons programs. India and Israel are the two most notorious examples. Iraq and North Korea are two further examples. Iraq's research reactors have been bombed by Israel, Iran, and the USA, because of suspected weapons production. In sum, the claim that no research reactor has ever adversely impacted its community holds up only if one ignores: fatal accidents; the waste management "crisis"; and the proliferation of nuclear weapons!
ANSTO claims that the radiation dose received during a diagnostic nuclear medicine procedure is "medically insignificant". This is incorrect. It is acknowledged by international expert bodies such as the International Commission on Radiological Protection (ICRP) that there is no safe dose for radiation exposure. The figure given by bodies such as the ICRP is a risk of 0.05 cancer deaths per Sievert (Sv) of low-dose exposure to ionising radiation. Using this figure, a study by the Australian Radiation Laboratory concluded that diagnostic nuclear medicine was responsible for approximately 56 fatal cancers in 1991. Taking into account the growing use of nuclear medicine, approximately 144 patients subjected to diagnostic nuclear medicine procedures in 1997 will subsequently die from cancer caused by the radiation exposure. ANSTO says that by the year 2007, there will be 1.5 million nuclear medicine procedures in Australia. Thus it can be calculated that approximately 495 of these 1.5 million patients will die from cancer caused by the radiation exposure associated with these "life-saving" procedures. In its submission to the Senate Nuclear Reactor Inquiry, the Sutherland Shire Council points to recent American research which indicates that the health impact of radiation has been underestimated by as much as a factor of ten. This gives us an alarming figure of almost 5000 deaths from nuclear medicine in Australia in the year 2007. (The American study is the Santa Susana Field Laboratory Epidemiological Study: Report of the Oversight Panel, 1997.)
In recent years, at least six research institutes have found new evidence linking radiation exposure to genomic (genetic) instability which can, in turn, lead to mutations in future generations. According to Dr. Eric Wright, a radiobiologist from the British Medical Research Council: "There is no doubt that genomic instability is a real consequence of radiation exposure." Apart from the possibility of inducing cancer in future generations, radiobiologists are concerned that radiation-induced genomic instability may cause a "scattergun effect" - small increases in a wide range of diseases including defective foetal development, and brain disorders such as Alzheimer's, Parkinson's and motor neuron diseases. (Edwards, Rob, "Radiation Roulette", New Scientist, 11 October, 1997, pp.37-40.)
When confronted with data on iatrogenic (medicine-caused) diseases, the nuclear industry typically responds by claiming that nuclear medicine does far more good than harm. This may well be true, but the evidence to support such assertions is very thin. Indeed it is openly acknowledged in the medical-professional literature that cost-benefit analyses are in a rudimentary stage of development in nuclear medicine. For example, Dr. Patton, a nuclear physician writing in Seminars in Nuclear Medicine, notes that "Costs associated with nuclear medicine procedures include money, time, discomfort, possible drug reactions, radiation dose, and the hypothetical risk of radiation-associated cancer. .... Much work remains to be done in forming a coherent, consistent procedure for assessing cost-effectiveness in nuclear medicine." Dr. Derek Roebuck, a radiologist writing in the Medical Journal of Australia, argues that the risk of causing malignant tumours through diagnostic tests involving ionising radiation - especially nuclear medicine, x-radiology, and computerised tomography - is widely underestimated, and that many new tests have been introduced without clear evidence of their net benefit to patients or their comparative advantage over alternative tests, and without precise evaluation of the radiation dose delivered.
ANSTO says: "An independent assessment has concluded that significant economic benefits arise from ANSTO's activities. It indicated that its research and development has a major beneficial impact in the minerals sector, with an estimated annual gross benefit of at least $100 million." In the Australian Financial Review (24 September, 1997), journalist Peter Fries questioned this "independent assessment" on the grounds that the figures make no allowance for waste management costs, decommissioning costs, or even ANSTO's annual operating budget of $60+ million. Prof. Max Brennan, former Chair of the ANSTO Board, was asked on the ABC's Lateline program as to the methodology of the above-mentioned study. Probably the same short of "shonky" approach that typifies these studies, Prof. Brennan said!
Prof. Ken McKinnon, Chair of the 1993 Research Reactor Review, said on ABC Radio on March 29, 1998:
"There is no way that a research reactor, a new one, built in Australia, would ever make a return on the investment for scientific, commercial and medical uses, which would even get towards a fraction of what it would cost for a cost-benefit analysis on the normal industry basis."
In a press release (3 September 1997), former science minister Peter McGauran said "The reactor .... will create up to 800 new jobs during the building phase." Ms. Danna Vale MP says "The decommissioning of the old reactor and the construction of the replacement will create over 800 new jobs in the Shire." However according to Senator Lundy, ANSTO said in its submission to the 1993 Research Reactor Review that a new reactor would create just 175 jobs.
Prof. Garnett said ANSTO was not involved in arriving at the estimate of 800 estimates. ANSTO has however said that 3600 person-years of employment will be generated during construction of the reactor. How does ANSTO justify this claim? Is it true that in 1993, ANSTO projected no more than 175 jobs? How can the 1993 information from ANSTO be squared with the 1997/98 information?
AECL (Canada) is building two reactors plus an isotope processing facility and expects that this will create just 500 person-years of employment. Even allowing for the fact that ANSTO plans a multipurpose reactor, as opposed to the simpler isotope-production reactors in Canada, the claims made by ANSTO, Mr. McGauran and Ms. Vale appear to be well beyond the realms of possibility.
No figures have been provided as to potential employment arising from pursuing alternatives to a new reactor at Lucas Heights, such as cyclotrons or spallation sources.
PPK Environment and Infrastructure Ltd., the company hired by ANSTO to assist with the Environmental Impact Assessment, claims that a new reactor will be used for "world class research". However, International Atomic Energy Agency data reveals that there are 20-25 research reactors around the world with a neutron flux equivalent to, or greater than, the neutron flux of the planned new nuclear reactor in Australia (3 x 1014 neutrons/cm2/sec). It is simply not possible to carry out "world class" research when so many reactors will outperform the planned new reactor in Australia. The Australian Academy of Science says that "In order to compete with the comparable medium-flux facilities overseas, the new Australian reactor should have characteristics such as a power of about 30MW, producing a flux of about 8 x 1018 neutrons/m2/second." The power and neutron flux of the proposed reactor is about half that recommended by the AAS. In other words, the AAS implicitly acknowledges that the proposed new reactor will not be able to compete with comparable facilities overseas.
Proponents of a new reactor claim that the proposal to replace HIFAR has strong support within the science community. This claim cannot be supported. The 1992 Australian Science, Technology and Engineering Council (ASTEC) report on major national research facilities is held up as "evidence" of support from the scientific community for a new nuclear reactor in Australia. In reality, ASTEC merely did a preliminary sifting of dozens of proposals. During the RRR, ASTEC said a decision on a new reactor ".... must not be based solely on the needs of scientific research and industrial production. It must also take account of a number of social, political and cost factors. .... The detailed, rigorous evaluation advocated by ASTEC has yet to be made - ASTEC sees this as the responsibility of the RRR."
Prof. Barry Allen - Fellow in the Department of Pharmacy at the University of Sydney, Head of Biomedical Physics Research at the St. George Cancer Care Centre, former Chief Research Scientist at ANSTO, and author of over 220 publications - made the following comments in Search, the official publication of the Australian and New Zealand Association for the Advancement of Science: "(The new) reactor will be a step into the past .... (It) will comprise mostly imported technology and it may well be the last of its kind ever built. .... In fact, the cost of replacing the reactor is comparable to the whole wish list that arguably could be written for research facilities by the Australian Science, Technology and Engineering Council (ASTEC). .... Apart from the neutron-scattering element of the reactor, there will be little research and development yet it will make a large dent in the budget for Australian research, which at this point is so badly needed in order to take us into the next century."
Dr. John Stocker, who holds the government position of Chief Scientist, and is also Chair of the government's advisory body the Australian Science, Technology and Engineering Council (ASTEC), says that neither the Office of the Chief Scientist nor ASTEC were consulted by the government before announcing the decision to replace HIFAR. The current head of the CSIRO has declined to comment on the proposal to build a new reactor, and said that he was not consulted about the proposal to replace HIFAR. Are we seriously expected to believe that the government wants a reactor for scientific research when the government did not even consult its main science advisers?
In 1993, the head of the CSIRO said that it could not support a new reactor if funding was not addition to usual science funding, and that "CSIRO is of the general opinion that more productive research could be funded for the cost of a reactor." Prof. Ian Lowe, from Griffith University, analysed the reactor/science debates during the RRR and concluded thus: "In summary, science policy considerations suggest strongly that a new research reactor should not be a high priority for Australia's small public sector research budget." The RRR (pp.65-66) said: "The Review was not even convinced that (reactor-based) science has been a major focus of ANSTO activity. The full flowering of recent vigour might not be evident yet in publications, but at present the case for a new reactor on science grounds cannot be sustained, however compelling the need for such science."
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