18 December 2017
Ref: R17/13702
Dr Larry Marshall
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Chief Executive Officer
CSIRO
PO Box 1700
CANBERRA ACT 2601
Request for Updating Waste Inventories
BY
Dear Dr Marshall
Background
ARPANSA
This request for action relates to radionuclide inventories of controlled material1 held by you that is, or is
likely to be considered as radioactive waste. This is material for which no further use is foreseen, but still
requires to be stored, until ultimate disposal is possible, and as such requires to be licensed under the
ARPANS Act. In particular, this request for action concerns low‐level radioactive waste (LLW)2 intended for
disposal at any proposed future National Radioactive Waste Management Facility (NRWMF) and stored
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intermediate level waste (ILW) pending a decision on its full life‐cycle management3.
The Department of Industry, Innovation and Science (DIIS) is pursuing plans for establishing a NRWMF, where
currently three sites in South Australia are under consideration. As you are aware, predisposal management
(such as storage and conditioning) is a key aspect of ultimate disposal that can only be carried out if the waste
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conforms to agreed Waste Acceptance Criteria (WAC), developed for the waste management facility or
facilities in question. Such WAC will form part of the safety case for the facility and will be subject to
regulatory approval. As plans progress towards the establishment of a NRWMF, a comprehensive
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understanding of Commonwealth waste holdings (e.g. radionuclide activity content and concentrations,
volumes, chemical and physical properties, waste matrix and other relevant characteristics) is essential for
the development of the WAC and will enable informed regulatory decisions to be made regarding waste
management facilities such as the NRWMF.
I am aware that, across Commonwealth licence holders, the waste under consideration may not have arisen
from activities carried out by the current entity holding the licence, but emanates from activities carried out
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by one or several of its predecessors or collaborating entities, and thus constitutes what is commonly referred
to as ‘legacy waste’. In some situations activities were at that time considered justified but an appropriate
infrastructure for the full life‐cycle management of resulting waste was lacking or incomplete. Actions were
1 Any natural or artificial material, whether in solid or liquid form, or in the form of a gas or vapour, which emits
ionizing radiation spontaneously (section 13 of the ARPANS Act).
2 Information on waste categorisation is available in Radiation Protection Series 20
Safety Guide for Classification of
Radioactive Waste (ARPANSA 2010)
3 Current plans for ILW management involve storage at the NRWMF but as yet not disposal.
619 Lower Plenty Road, Yallambie VIC 3085
38–40 Urunga Parade, Miranda NSW 2228
xxxx@xxxxxxx.xxx.xx
+61 3 9433 2211
PO Box 655, Miranda NSW 1490
arpansa.gov.au
+61 2 9541 8333
therefore taken to store and, as applicable, condition the waste so that it would not pose immediate or
medium term radiation risks of any significance for people (workers and the public) and the environment.
However, in the absence of a final management framework, including ultimate disposal of the waste, it could
generally not be characterised and/or conditioned to meet WAC for facilities for final management in mind.
Nevertheless, controlled material held by you must come within the scope of your licence, regardless of its
origin, and if it is not accurately recorded in your source inventory then it must be regarded as an unlicensed
dealing under the ARPANS Act. Further, maintaining an updated source inventory is a licence condition.
Based on the above, the current licence holders have to assume responsibilities for the legacy from previous
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activities even though they might not have been part of such activities, and are, therefore, required to keep
their source inventories accurate and up to date. Uncertainties may affect plans to ultimately dispose of the
waste, either in a NRWMF or through other means.
Current status
Recent inspections performed by ARPANSA have identified instances where ‘legacy’ sources of radiation may
BY
not have been recorded, or have not been accurately and completely characterised in source inventories.
Moreover, discrepancies have been identified in inventories held by licence holders and by ARPANSA. Some
ARPANSA
licence holders have proactively come forward and advised ARPANSA that their radionuclide (source)
inventories may not have been fully up to date. I appreciate the openness licence holders have demonstrated
in relation to legacy waste holdings, as well as their constructive approach to resolution of this issue in the
interest of safety and protection of people and the environment.
Contributing factors to current uncertainties include, but are not limited to:
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legacy controlled material and controlled apparatus have been stored away for several years and
limited records were previously maintained;
corporate knowledge has not been appropriately maintained; and
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characterisation of legacy materials conducted in the past may not conform to the modern
scientific standard.
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Based on the above, it is timely that licence holders review their radionuclide inventories and as necessary
update the inventories as well as relevant information that will support the standard elements of the WAC
for the NRWMF. ARPANSA intends to verify the inventories through inspections and, if necessary,
measurements
in situ or at ARPANSA’s laboratories, and will cross‐reference inventories with records held
by ARPANSA. It is anticipated that such verifications will, normally, be carried out within 12 – 18 months of
today’s date.
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ARPANSA is not aware of any information that would raise concerns for harmful effects to people and the
environment from past practices, or that there is any pressing risk to the health and safety of people and the
environment. Nevertheless, actions need to be taken to mitigate potential hazards, for the purpose of
protecting the health and safety of people and the environment for the long term and for as long as the
hazardous properties of the waste pose a radiation risk of concern.
Consultation
Relevant licence holders have been advised in advance of this request for information and ARPANSA has
considered the specific situation licence holders may envisage on a case‐by‐case basis. ARPANSA will
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continue to provide guidance while emphasising that the ultimate responsibility for safety rests with the
operator.
The DIIS, having policy responsibility for the NRWMF, was informed of my intention to make this request.
The verifications carried out by ARPANSA will not bind or pre‐empt regulatory decisions in relation to the
NRWMF (a positive decision by the CEO of ARPANSA is required for preparing a site; construction; operation;
decommissioning of a storage facility and ancillary facilities; and for abandoning a site and surrendering a
licence), but will facilitate the review of a licence application, should ARPANSA receive one.
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Yours sincerely
BY
Carl‐Magnus Larsson
CEO of ARPANSA
ARPANSA
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