SA NUCLEAR FUEL CYCLE ROYAL COMMISSION

MR KEVIN SCARCE, Presiding Commissioner MR CHAD JACOBI, Counsel Assisting

SPEAKERS:

Dr Edwin Lyman, Union of Concerned Scientists Mr Frank Boulton, Class 7 International Pty Ltd Mr Jack Dillich and Dr Samir Sarkar, Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) Mr Hefin Griffiths, Australian Nuclear Science and Technology Organisation (ANSTO) Mr Alastair Brown, International Nuclear Services (INS)

TRANSCRIPT OF PROCEEDINGS

ADELAIDE

7.30 AM, TUESDAY, 17 NOVEMBER 2015

DAY 23

PROCEEDINGS RECORDED BY SPARK AND CANNON

.SA Nuclear 05.11.15 P-512 Spark and Cannon COMMISSIONER: Good morning. The topic for today's discussion is transportation of nuclear materials. We have Dr Edwin Lyman from the Union of Concerned Scientists; Mr Frank Boulton, an expert in transport; Dr Samir Sarkar from the Australian Radiation Protection and Nuclear Safety Agency; 5 and Mr Hefin Griffiths from ANSTO. Counsel.

MR JACOBI: An analysis of the security and safety of transportation of nuclear and radioactive materials arises for consideration under each of the commission's terms of reference. Transportation of those materials is a 10 necessary element of the operation of facilities to mine or mill uranium, process nuclear fuels, generate electricity through the use of nuclear fuels or to store or dispose of radioactive wastes. The management and coordination of the transport of nuclear materials is essential to the safe and secure conduct of those activities. 15 This analysis arises against a backdrop where nuclear and radioactive materials have been transported throughout Australia, particularly within South Australia, for many decades. Most relevant to South Australia, this includes uranium ore for processing and export, sealed radioactive sources for use in 20 medicine and industry, and radioactive wastes which are produced by those and other industrial operations.

The Commission has received submissions which raise concerns as to the risks that such materials present to human health and the environment while being 25 transported, particularly in the scenario of an accident or an inadvertent error, and the possibility that such materials might, in the process of transport, be vulnerable to deliberate attempts to acquire those materials the issue of security. Before it could consider recommending any expansion in mining or the establishing of further nuclear activities in South Australia, the commission 30 would need to consider the magnitude of the risks, the likelihood of an unintended outcome taking place during transportation, such as accident or theft, and the measures which are in place to manage those risks during transport.

35 In the case of nuclear materials, these measures include physical barriers which are built into their packaging for transport, approvals processes and emergency management strategies. In the context of the packaging of nuclear materials, the commission will turn its mind to the appropriateness of the testing requirements which apply and whether they sufficiently simulate accident 40 conditions. As part of its inquiry, the commission will today speak to those who have analysed the risks associated with transport to manage the transportation of nuclear materials in Australia both domestically and those who are responsible for giving approvals for the safety of the packages in which those materials are transported. 45

.SA Nuclear 17.11.15 P-1241 Spark and Cannon The commission's first witness today, Dr Edwin Lyman, is a senior scientist in the global security program at the Union of Concerned Scientists in the United States. His areas of interests include nuclear proliferation, terrorism and nuclear power safety and security, and he's published articles in a number of 5 journals and magazines on these topics. Dr Lyman is a member of the Institute of Nuclear Materials Management and has given evidence before the US Congress and Nuclear Regulatory Commission, the NRC, on multiple occasions.

10 Prior to joining the Union of Concerned Scientists, Dr Lyman was president of the Nuclear Control Institute, the CI, in Washington, an organisation concerned with nuclear proliferation. The commission calls Dr Edwin Lyman.

COMMISSIONER: Thank you, Dr Lyman, for joining us this morning our 15 time, this afternoon your time. In a paper that you presented in Kuala Lumpur on the carriage of ultra hazardous radioactive cargo by sea you chronicle a number of accidents that occurred and you drew a conclusion that said, in essence, the general erosion in quality control, maintenance, respect for procedure, regulatory oversight, which is manifest both from an increasing 20 need on the part of nuclear industry to cut costs and from a complacency which resulted from the excessive and unjustified confidence the industry has in its own safety record. Then you go on to say that it's a very dangerous trend, with serious ramifications. Is there anything that's occurred since that paper was written in 1999 that you think might have changed those circumstances? 25 DR LYMAN: Thank you for your question. With the caveat that I have not followed transport accidents of nuclear materials since then but I have become more interested in general issues with nuclear safety, including nuclear power safety, then I would say that certainly the Fukushima accident in 2011 was a 30 confirmation of those words that I wrote back in 1999. I think it's generally accepted that it was complacency, lack of advanced planning, lack of consideration of severe accidents that all contributed to the inability of the Japanese to cope with the Fukushima accident. So I think that that mindset was prevalent and continues to be prevalent regarding the management of 35 nuclear activities, whether it's power generation, transport or waste disposal.

COMMISSIONER: I might ask counsel assisting now to move on and discuss some of those transportation issues that arise from your paper.

40 MR JACOBI: Dr Lyman, I'm hoping to pick up one of the key themes of the paper was a view expressed with respect to the adequacy of the protection which was provided by the Type B standards which are recommended for the packaging of transport. I'm just wondering perhaps whether you might expand on your view with respect to the adequacy of the protection that's provided by 45 those standards and the views you'd expressed.

.SA Nuclear 17.11.15 P-1242 Spark and Cannon

DR LYMAN: Thank you. With Type B standards for transportation casks for land or sea shipment of spent fuel, high-level radioactive waste and specially with materials like plutonium or plutonium oxide, the standards have not 5 changed in many decades and so I think the objections that I raised within this paper are still true today; that the standards represent a certain percentage of the kinds of conditions that might be experienced in a transportation accident but it still is not well defined exactly what percentage of plausible transportation accidents those standards would protection against. Also, the 10 governing philosophy behind those standards is the notion of graceful failure; that is, in the real world, yes, you may experience accidents that are far more severe than the Type B standards would simulate but the packages are designed so that they would not fail catastrophically if you just exceeded those conditions by a small amount but they would fail gracefully. 15 In my analysis back then I called into question the issue of whether graceful failure is something which is built into many different types of radioactive material transportation casks. So if you look at the case of the seal design or (indistinct) seals for the lids of radioactive material transportation casks, those 20 generally do not exhibit in my view a graceful failure (indistinct) of the duration required by the Type B standards, and especially talking about long duration fires and we've certainly seen transportation fire within the United States that was the famous Baltimore tunnel fire which greatly exceeded 30-minute fire transportation. So certainly we can experience accidents that 25 are greatly in excess of those parameters.

I argued then, and I continue to argue, that if you want to understand whether or not these packages actually (indistinct)

30 COMMISSIONER: I'm sorry, Dr Lyman, we've just lost the audio for a moment.

DR LYMAN: (indistinct) shipping casks to actually represent - I'm sorry, can you hear me now? Can you hear me at all? 35 COMMISSIONER: No.

DR LYMAN: Sorry.

40 MS ...... : We can hear you but it's cutting in and out, Dr Lyman.

DR LYMAN: Can you hear me now?

COMMISSIONER: Yes. 45

.SA Nuclear 17.11.15 P-1243 Spark and Cannon MR JACOBI: Yes, we can.

DR LYMAN: Should I go and try to call back?

5 COMMISSIONER: No.

DR LYMAN: Can you hear me?

COMMISSIONER: No, I think - - - 10 DR LYMAN: Does that sound good?

MR JACOBI: I think we're fine. Perhaps we can move on. Because I think we missed part of your answer, perhaps if I could ask this question because I 15 did want to come to this question of the view with respect to graceful failure and I was interested to understand, is there any evidence that in fact, that the packages or the flasks that have been designed for Type B purposes would exhibit cliff edge effects beyond the scenario for which they’re designed.

20 DR LYMAN: Well, I think I gave some examples in the paper, of failure mechanisms that may actually be cliff edge effects, but I think the larger issue is that there’s no regulatory requirement or standards to not encourage or require the graceful failure to be built into packages. They’re standards which are set, and the package designer (indistinct) comply with those standards, so 25 having a graceful failure (indistinct) and depth is not a separate requirement.

So you might have packages more robust than others because of their purpose, but they were not designed for graceful failure, so the only way to really demonstrate it is to do full scale testing under - beyond design basis conditions. 30 So to that end, I would point to a study that was proposed here in the US by the Nuclear Regulatory Commission, it was a package performance study. It was actually proposed that they would conduct tests under greater impact and fire conditions than Type B standards now represent.

35 But that study, for budget and planning and other reasons, was actually never carried out, so I think there’s still a large uncertainty that that study was meant to address, that has not been addressed.

MR JACOBI: Can I just pick up part of your answer there, and that is that 40 I’ve read a number of reports of studies conducted by glass manufacturers and others, where they’ve tested components or indeed, scale versions of their flasks beyond their design limits. What’s the reason for your emphasis on testing a full scale model, given some of the difficulties associate with for example, using compression chamber and the size of a compression chamber 45 for an immersion test?

.SA Nuclear 17.11.15 P-1244 Spark and Cannon

DR LYMAN: Well, I’m not the mechanical engineer. I would just say that I think there is a recognition that testing scale models does not always accurately capture phenomenon that may occur at full scale, and that’s because generally, 5 let’s say these occlusion, these processes are non-linear and may not scale. So you may lose some effects that you’d only see at full scale.

So I think there is a recognition that scale models may not capture all the physical phenomenon that you would see at scale, and that’s why, for instance, 10 the package performance study on a full scale package was recommended. So I refer you to the rationale for that study, for further (indistinct)

MR JACOBI: As I understood it, the package performance study was to be a fire and impact analysis. The particular question I was raising was with respect 15 to immersion. Do you think there - - -

DR LYMAN: (indistinct)

MR JACOBI: - - - might be a possibility for differentiation, depending upon 20 the nature of what it is you’re seeking to analyse?

DR LYMAN: So the question of whether scale on models, or accurately capture immersion - I don’t - I can’t really answer that question at this point. I would just say that the immersion test simply does not capture the scenario that 25 I outlined in the paper, that is if you lose a package of radioactive material, transport package, in a region of the ocean where it can’t be salvaged and it has to be abandoned, then the question is what kind of long term radiological contamination can result from that package. And I think it was demonstrated that because of the very large concentration of radioactive isotopes, particularly 30 caesium-137, as well as certain actinides like amoresium 2.1, and a (indistinct) of spent fuel in a high level waste transport package, but that could lead to significant long term contamination if the package is not retrieved.

So long term immersion, and the impact of salt water on (indistinct) seals and 35 that phenomenon (indistinct) need to be considered.

MR JACOBI: Okay. Can I come back to a part of your answer from before, and that is you expressed a view about whether the testing took account of the full range of, I think, the realistic accident scenarios, and I’m just interested 40 whether you can indicate that you’re of the view that there are scenarios that are likely to be more severe than the testing regime.

DR LYMAN: Well, I think the guidance document for the package performance study, part of that was going to update these test (indistinct) of 45 transportation accidents, because the IEA standard (indistinct) a certain period

.SA Nuclear 17.11.15 P-1245 Spark and Cannon of time, a certain database of transportation accidents and that has not been updated at least to the standard that the NRC would have confidence in. And in the US, we’re in the area where if we do proceed towards (indistinct) there’s (indistinct) significant increase in the frequency of transportation of spent fuel 5 for decades.

So there needs to be a greater assessment of the current standards and the current conditions for transport. So in the United States, speed limits have increased significantly over the last couple of decades in many states, and that 10 was not taken into account in the US government’s incorporation of IEA standards (indistinct) so issues like that need to be fully addressed, at least from the point of view of the United States.

MR JACOBI: I think, to pick up something you said before, are you of the 15 view that the standards ought contain a very clear statement of the probability of the sort of scenario that they’re protecting against? That is, that it’s something that could be quantified and ought be expressed in those terms.

DR LYMAN: Well, it can be quantified, the uncertainties however can be 20 large, because it’s hard to see if extrapolation from you know, transportation statistics - we’re talking about events that are low probability, but it’s hard to actually define how low probability they are, because in some places you’re extrapolating from known events to less frequent but more severe events, and you know, how you do that extrapolation is not necessary well defined. 25 So you know, you can get a rough sense I would say from that approach, but you can’t get a very precise quantitative estimate of how much protection any given standard is going to afford. Then the other issue is the prospect of terrorism, which I hope we can touch on, because in that case, if you’re going 30 to do a nuclear act, then you can’t quantify the probability of other ways to achieve confidence in safety and security.

MR JACOBI: The issue of security associated with transportation of these materials: much of the views expressed with respect to security are expressed 35 with respect to the package, and I’m just interested to the extent to which the package in your view can provide relevant security against those sorts of risks.

DR LYMAN: I mean, clearly the institutional managers and the human factors and problems of protection are significant, but certainly a raw form of 40 the type of package to increase the resistance to certain types of sabotage. So you know, there is (indistinct) design (indistinct) packages, but for sabotage we’d need to know what particular scenarios you’re talking about to find the (indistinct) so in the US, there are a range of dry casts which are certified both for storage and for transport, and they vary with regard to the potential of 45 radiological release if that occurred in a given attack of say, a shape charge

.SA Nuclear 17.11.15 P-1246 Spark and Cannon attack.

We certainly can design better packages, but that is not going to solve the problem completely as any package will have failure modes and depending on 5 the ability of an adversary to access that package will determine to what extent they can damage it and potentially release the contents. So with (indistinct) it's going to need physical protection and all the elements associated with that but also better packaging would certainly provide an additional layer of security.

10 MR JACOBI: I was hoping that we might be able to discuss - because we're aware that you've published with respect to IFRs and I was just hoping you might be able to pick up some things with respect to fast reactors this morning as well, in addition to dealing with transport. I understand you've expressed some views with respect to the ability of IFRs to reduce the longevity of the 15 need to store waste; that is, the ability for them to use and burn up the transuranics. I'm just interested if perhaps you might express those views.

DR LYMAN: The IFR or the integral fast reactors were a concept of a liquid-metal cooled metal-fuelled fast reactor with an integral higher 20 processing system that would extract actinides from spent fuel and fabricate fresh fuel from that. So the idea that that system could be used to "burn" actinides (indistinct) technology, but there's been substantial work on the potential performance of fast reactor systems in general or the IFRs types in particular that demonstrate that it's a misleading picture to say that these 25 systems can simply burn up nuclear waste and eliminate or greatly reduce the need for a geological repository. Those I think are a gross exaggeration of the capability of those systems and possibly the overarching aspect is that the systems actually are very sluggish with regard to the quantity of actinides that they can actually consume in any given cycle. 30 So certainly there are many analyses and references but look at fast reactor systems (indistinct) reactors but they consider the impact of this fast reactor systems on the total quantity of actinides within the system. That means not just the actinides that are left in the waste after extracting them but also the 35 actinides that are incorporated into the coils of fast reactors. So you have to look at the entire fuel site. If you do that, you see that even if you have a system with very high performance burner reactors with a very high conversion ratio (indistinct) which cycle they would consume a large fraction of the actinides in the fresh fuel, it still takes hundreds or even thousands of years to 40 make a significant dent in that total quantity of actinides in the system.

So the question is, if you're trying to reduce the need for a geological repository for power generators, you'd like to see a six-point theory but actually saying you can achieve that within our own lifetime. But if it takes many 45 hundreds or thousands of years to make a significant dent in that total quantity

.SA Nuclear 17.11.15 P-1247 Spark and Cannon of actinides then we're not really achieving it. Instead of leaving it to future generations and geological repository, you're saying you'd have the system of fast reactors almost ad infinitum in order to achieve the reduction that you have originally anticipated. So I don't see that as really fulfilling the 5 intergenerational equity aspects of nuclear waste disposal if our generation spends hundreds of billions of dollars to construct a fast reactor and a processing system to burn off actinides when 50 or a hundred years from now only a fraction of that total quantity reaction will be burnt. So leaving 90 per cent or 80 per cent of that to the next generation I don't think achieves 10 that goal. It's not a very - - -

MR JACOBI: Can I just pick up your answer then in terms of the duration of the time period for actually burning up the actinides in such a system. Is it possible to design the system in such a way that it's possible to reduce or limit 15 the sorts of time periods we're talking about, such that we can be quite precise about the time period that it would take to burn up the transuranics that are used in the fuel?

DR LYMAN: Well, you can calculate it precisely, but again referring to 20 studies that do just that but there's no (indistinct) parameters of such a system, even again with very high - if your goal is burning up actinides and maximise the burning capability of the fast reactors, even then it still takes a very long time to achieve these goals. So you can do those calculations but there's seems to be practical limits - not just practical but theoretical limits - on how quickly 25 we could actually physically impact actinides, and that doesn't even take into account a whole host of other associated problems with a fast reactor fuel site.

MR JACOBI: I will deal with a couple of those in a second. I'm just interested to understand even if one was seeking to do it on the shortest time 30 period, are we still looking at a period of time beyond the lifetime of the particular piece of plant itself?

DR LYMAN: From the studies I've seen, the best performance would still take a hundred years or more to, let's say, reduce - and this is just off - I'd have 35 to consult the references - but to reduce the quantity of actinides by a factor of 10, which I would think would be the minimum requirement for such a system. That would probably take upwards of a hundred years or more and that's assuming very aggressive of burner reactors and there are actually a lot of safety issues associated with fast reactors generally but the burners introduce 40 additional questions about safety. So it's not even - these are just theoretical studies that don't even consider all those additional issues. But even if it's doing as well as we might think theoretically, it would still take a long time.

MR JACOBI: The Commission would be interested in receiving the 45 references. So if you'd be prepared to send them through, it would be assisted

.SA Nuclear 17.11.15 P-1248 Spark and Cannon by those that point to certainly the limits of the time periods that we're talking about.

DR LYMAN: I'd be happy to. 5 COMMISSIONER: Dr Lyman, you may not have a view on this but if you've been following IFRs do you sense how long before they might become commercial?

10 DR LYMAN: In my view, and the view of many other experts - I mean it's really a country-dependent issue but the question of development and deployment of advanced reactors, just taking the United States as an example, it's a very, very challenging issue because we haven't established fully light-water reactors and our industrial experience, operating experience, 15 industrial base and regulation are all keyed towards light-water reactor systems. What's needed to actually develop a licence in advanced reactors like a fast reactor is very expensive and best estimates of organisations like (indistinct) is that it's an enterprise around the order of tens to hundreds of billions of dollars to actually bring an advanced reactor design to the point 20 where it could be commercialised, and it would take several decades (audio malfunction) the United States went full bore to try to develop and employ an advanced reactor but still not (indistinct) and it could cause many tens of millions of US dollars.

25 MR JACOBI: Okay.

DR LYMAN: So it’s quite a challenge, and it also raises the issue of government versus private investment for utilities, which will be the customers for advance reactors are very conservative and they’re not interested in long 30 term investment to support R & D, and that investment (indistinct) in the US.

MR JACOBI: Can I just come to address a number of the other issues associated with reactors - sorry, those reactors that you’ve spoken about, and can I come first to the issue of the proliferation related consequences associated 35 with those reactors? The Commission has heard competing views with respect to those matters, depending upon particularly the proliferation resistance and the pyroprocessing, and I’m just interested, perhaps you can express your views with respect to what you think the proliferation related impacts might be.

40 DR LYMAN: Yes. I’ve studied in great detail pyroprocessing systems in so called proliferation resistance, and it’s my view, and there a number of published papers on this, that pyroprocessing does not confer any significant advantage over aqueous reprocessing with regard to proliferation and terrorism. The separation of actinides in pyroprocessing systems leads to products which 45 are attractive for an adversary that seeks to make nuclear weapons, both

.SA Nuclear 17.11.15 P-1249 Spark and Cannon because many actinides other than pleutonium-239 are weapons useable, but also because the radiation character associated with the products of pyroprocessing does not act as a significant deterrent to theft or diversion.

5 So there’s been a great exaggeration with regard to the proliferation resistance of pyroprocessing. I might also indicate that one of the largest components of a pyroprocessing product with regard to the radiation (indistinct) isotopes that are highly radioactive, that emit penetrating gamma rays and create a very high radiation dose (indistinct) deterrent for someone seeking to physically handle 10 or transport that. The radiation barrier that is conferred by certain lanthanide fission products, and those lanthanide fission products are not desirable in fuel fabrication or fuel re-ignition and cast reactors, so most current concepts for fast reactor or IFR-like systems would require additional steps to remove (indistinct) fission products, therefore reducing the permanent radiation barrier. 15 So if we actually look at what is practical to be done for the system, we find out that we don’t really get that advantage. Certainly, nothing would be a significant amount for us to say (audio malfunction) around the world without significant concern for proliferation. 20 MR JACOBI: As I understand it, the view you’ve expressed there is that the removal of certain elements, which are the lanthanide elements in the period table diminishes its radiation deterrence. I’m just interested, with respect to the balance that’s left, does that not still pose a significant radiation deterrence? 25 DR LYMAN: No, because what’s left is primarily plutonium, uranium and minor actinides. So nuclear actinides have nektonic gamma dose, but if you actually look at the dose rate from those products, it’s still more near what’s considered to be a (indistinct) right now the International Atomic Energy 30 Agency defines one Sievert per hour at one metre radiation dose as what they consider a self (indistinct) which leads to a definition of what’s irradiated material in IEA guidance.

The dose rates associated with the minor actinides in pyroprocessing product 35 generally well below that, one Sievert per hour. And you also have the (indistinct) one Sievert per hour of one metre is not really considered to be a significant deterrent to a suicidal terrorist, for example. In the United States, those terrorist considerations (indistinct) increasing that threshold to something like 50 Sieverts per hour, so the one Sievert per hour is probably at 40 the pyroprocessing product now getting (indistinct) and I am familiar with papers where they actually calculate the re-ignition from a dose from pyroprocessing products and find if it’s going to be a one Sievert per hour.

MR JACOBI: Just stepping aside from the issue of radiation deterrence, and I 45 just wanted to pick up the other aspects. You expressed a view that

.SA Nuclear 17.11.15 P-1250 Spark and Cannon pyroprocessing didn’t offer any particular advantage over the aqueous processing, which I understand is used to make Knox fuels. I’m just interested to the extent to which it shares characteristics that it would mean that it would have the same proliferation associated risks. 5 DR LYMAN: Yes. I mean, when you’re talking about proliferation, you have to also keep in mind the primary role of material (indistinct) and let’s say IEA safe products. But accurate accounting for special nuclear material is critical to be able to safeguard (indistinct) and for handling facilities like aqueous 10 reprocessing plants. For instance, like a plant that (indistinct) produced, if they were operating full scale, would produce many thousands of nuclear weapons worth of plutonium (indistinct) and that means a safeguard against the diversion of one significant quantity.

15 It’s an extremely daunting task (audio malfunction) now, when you talk about (audio malfunction) processing systems, they have lower (indistinct) generally than let’s say, a nuclear fast reactor, but there’s no safeguards approach currently to (indistinct) for pyroprocessing systems. Material accountancy is even harder in a pyroprocessing system than an aqueous system, because the 20 material flows are very heterogeneous, so sampling is very difficult. The materials tend to fade out on cathodes and you get very hard deposits that are hard to remove (indistinct) characterise, so there are big safeguards issues associated with pyroprocessing, and that would be a concern if there was a greater move toward (indistinct) systems. 25 And the IEA is still struggling to provide even technical approaches for how you would (indistinct) weapons grade accountancy in pyroprocessing, and that’s a great concern.

30 MR JACOBI: I’m interested in your view as to the - I’ve read in the submissions materials that suggested that the material produced from pyroprocessing and some other re-processing techniques would not be suitable for use in an atomic weapon, in the sense that the plutonium would still contain impurities that would make it unsuitable for such use. Do you have a view 35 with respect to that?

DR LYMAN: Yes. There of course are many types of aqueous and non- aqueous re-processing flow chutes that would separate different types of materials, but if you’re talking about let’s say the pyroprocessing flow chute 40 that would have plutonium, uranium and minor actinides of plutonium-237 and in the flow chute americium mercurium. Most of those minor actinides themselves are weapons (audio malfunction) comparable to (audio malfunction) 235, so the fact is - - -

45 MR JACOBI: I’m sorry Dr Lyman, can I just get you to repeat the last couple

.SA Nuclear 17.11.15 P-1251 Spark and Cannon of sentences? I’m sorry, we’ve just had a minor drop out.

DR LYMAN: Many minor actinides that would be in the pyroprocessing product were also weapons useable, because the materials with critical masses 5 comparable to the (audio malfunction) in the United States, neptunium-237 and americium-241 are required to be accounted for as if they were (audio malfunction) and so they are considered sensitive and weapons useable materials in the United States.

10 So minor actinides will not reduce the attractiveness of that combination for nuclear weapons. Now, that said, they present different technical challenges, but those technical challenges (audio malfunction) solutions, so you can’t bank on the presence of minor actinides to render the material unusable for nuclear weapons. 15 It’s also easy, if that combination were to be stolen, to separate out plutonium from the minor actinides. In fact, the standard solutions could do that. So if you were able to actually to steal the material and process it (indistinct) if you wanted to separate plutonium (indistinct) but the bigger is because it’s uranium 20 and the dilution factor, but again uranium and plutonium can be separated using an aqueous (indistinct)

So that brings me back to the presence of fission products that provide a radiation barrier, and those, like I said, generally would be removed from the 25 current (indistinct) advocated for your fast reactors, because they would have undesirable effects. So that means that pyroprocessing itself would have to be supplemented with some other purification process to make the fuel useable or practicable (audio malfunction)

30 MR JACOBI: Dr Lyman, I understand those matters and I hope I’ve got this correct, your view, that you have a preference for ultimately geological disposal, that is, a once-through fuel cycle, as compared to the use of these techniques?

35 DR LYMAN: That’s correct. We think that, for the same reasons that the United States decided not to pursue re-processing and fast reactors in the 1970s, that the proliferation and terrorism risks of a fuel cycle is based on weapons useable fuels, production and processing of weapons useable material (audio malfunction) very great quantity, and that that is certainly an 40 unmanageable enterprise, and that nuclear energy can be generated using low- enriched uranium or natural (indistinct) uranium, which is not a direct weapons useable material, and so there’s certainly something (indistinct) in the field of (audio malfunction) to use weapons useable fuels.

45 So we use the once used fuel cycle, based on low-enriched uranium fuel, and

.SA Nuclear 17.11.15 P-1252 Spark and Cannon direct disposal is the safest and the most prudent approach for nuclear power. And, there is no good rationale for close recycles in which the benefits have actually outweighed the risk.

5 COMMISSIONER: Dr Lyman, thank you very much for joining us this afternoon, your time. It’s very useful to have both those perspectives on transport and IFRs. We’ll now adjourn - - -

DR LYMAN: Thank you. 10 COMMISSIONER: Thank you - until 9 o’clock.

ADJOURNED [8.14 AM]

15 RESUMED [9.01 AM]

COMMISSIONER: We'll reconvene and I welcome, on the subject of the transportation of nuclear materials, Mr Frank Boulton. Thank you for joining us, Frank. 20 MR BOULTON: Thank you.

COMMISSIONER: Counsel.

25 MR JACOBI: Frank Boulton is based in Adelaide and provides consulting services in relation to the management of radioactive material consignments from mine sites to their points of export. He provides advice on matters including the practical operation of radioactive material transport supply chains, compliance with regulatory requirements and the establishment of 30 effective communication channels between all relevant bodies during consignments.

Mr Boulton is also the Australian representative for the World Nuclear Transport Institute, WNTI. In part of his current role, Mr Boulton worked in 35 the transportation of radioactive nuclear materials for over 30 years at Olympic Dam. The commission calls Mr Frank Boulton.

COMMISSIONER: Mr Boulton, if I could start with the basics, which is generally where I'll finish, can you explain the relationship between the role of 40 the package and safety and then move on to the relationship between the package and material, and then we'll move on to defence in depth. So the first - - -

MR BOULTON: Sure. The concept of the transport regulations is that the 45 package should adequately protect people and the environment from any

.SA Nuclear 17.11.15 P-1253 Spark and Cannon damage that may be caused by material contained within. That's the same as any sort of material, really; whether it's an acid, non-radioactive material. It applies the same sort of things. The package design has to protect the goods through normal, routine and accident conditions of transport. You take a 5 graded approach which depends on the potential hazard, the nature of the hazardous material. So low-level material there are less requirements than there are for the higher end materials.

These measures have been developed over a long period of time, over more 10 than 50 years. They're constantly updated - regularly updated. The main thing is containment of the package and containment of release of radioactive materials because with Class 7 we've got this radioactivity that people can't see but we need to contain it. So once again, depending on the package, if you've got just a small sample of material, you could probably put it in a padded 15 posted bag and send it as accepted package, whereas if you've got some spent fuel you might need to put it in a - you will put it in a stronger package because of the amount of radiation and activities coming from that material.

COMMISSIONER: That comes to the concept of defence in depth. 20 MR BOULTON: Yes, it does. Defence in depth is about the package strength and the type of package. It's also about adherence to the regulation, compliance with the regulation. The other part of defence in depth comes around having incident response; what to do in the case of an incident. It could 25 be a normal traffic accident, routine or high-end accident. So that's the defence in depth.

There's a further part, which is basically safety in depth, but that comes from encapsulation. The best way I can describe encapsulation is to think about the 30 Russian dolls. You know how the Russian dolls keep fitting in. The smallest doll might be a very high-level radioactive source, then a bigger doll which is a separate part of the package. As you move through, you're moving through - so you may have a source within a Type A package which is then in maybe packed in a shipping container and that shipping container is then put inside a 35 vessel which has a double hull. You understand the situation. So that's encapsulation. If anything happens you've got - so there you've got safety in depth. If there's a spill, it's certainly contained. Also you're protecting or you're minimising the effects of ionising radiation. Appreciating alpha, beta, gamma, gamma is the strongest but it's got so many layers of metal to get 40 through that you're really reducing that.

MR JACOBI: Can I come back to the concept of a graded approach. As I understand it, that requires some assessment of the material that is to be transported and I'm interested, first of all, in understanding that process of what 45 is the process of the assessment of the material involved and what's the

.SA Nuclear 17.11.15 P-1254 Spark and Cannon outcome of that assessment.

MR BOULTON: It's very important to assess the material. You need to understand the material. There's a broad range of stakeholders who need to 5 understand the material but principally the person shipping it; that's the first thing that you need to understand.

MR JACOBI: Can I just ask at this point is it a legal requirement to assess it before you transport it? 10 MR BOULTON: I think if you don't, you're not going to go very far, Chad. I think that's the issue, because you probably won't comply with the regulation. You really need to. But you need to understand what the material is. If you assess the material, determine whether it's actually radioactive. Does it contain 15 uranium methyl? If it does, is it low-specific activity. You start to build up a picture. That information then goes into your shipping documentation, it goes into your discussions with people.

MR JACOBI: Can I just come back to the assessment itself. So at the point in 20 which you've assessed the material, for example, is radioactive, what is the information that you then gather about the material in terms of being able to make relevant decisions with it?

MR BOULTON: You'll do some assessment on your materials, some 25 chemical analysis and you're only interested in the radioactive elements. So you might be shipping some mineral sands which could have - or it could be a copper concentrate. There may be some uranium in it. You need to determine how much there is; assess the radioactive elements, their parts per million; the quantity of material. You need to make some sort of a decision about how you 30 might be going to package this stuff. Based on that, you can then start to build a picture of this material.

MR JACOBI: Do you undergo a calculation with respect to analysing the extent to which it's radioactive; that is, the extent of its activity? 35 MR BOULTON: You can calculate the becquerel per gram; that's the radioactivity level. The dose rate, that's a little harder to calculate. It's a fairly complex calculation. What we recommend is it's better to take a reading of that material. Now, that can sometimes be a little difficult. It's okay if you've 40 got a small sample. You might have a sample bucket, you might have a 200-litre drum, a shipping container even. Maybe if you're going to put this stuff into the hull of a vessel that could be a bit difficult because you're going to have to put it there and then take a reading. But it is important to take a reading, where possible. 45

.SA Nuclear 17.11.15 P-1255 Spark and Cannon MR JACOBI: The commission understands that something is calculated called a transport index. Can you explain what the transport index and its relationship in the assessment.

5 MR BOULTON: Once you've got your activity level, the transport index is a multiplier of that activity level basically. It's just a figure that is used to help understand where this material fits in the scheme of the transport. Shippers use it. They will quite often along and they will set an arbitrary number. They might say, "We'll take a total transport index of a hundred on any vessel." 10 Then you can calculate how many shipping containers. People use it in that way at times.

MR JACOBI: Does the assessment lead to a categorisation?

15 MR BOULTON: Lead to a categorisation?

MR JACOBI: I think we've got a slide up that shows what we understand to be the assessment process. I'm just wondering perhaps whether you could walk us through the left-most slide and explain to us in broad terms what that's 20 showing us.

MR BOULTON: What we've got here is we've got some material. We're going to put this in an ISO container with some drums, or similarly it could be Bulka bags - A, B, C Bulka bags. 25 MR JACOBI: An ISO container is just a shipping container.

MR BOULTON: A shipping container, a standard 20-foot shipping container. The reason why it's a 20-foot shipping container, you don't get much value in a 30 40-footer. They're bigger, they're harder to handle and you don't get much more tonnage. Receivers normally can't handle 40-footers. So we've got an assessment of parts per million of thorium and uranium. We've got the dose rate in millisieverts at the surface and at one metre. We've assessed it; yes, the material does contain uranium and thorium. 35 MR JACOBI: I think picking up that gamma dose rate that's measured, that's an actual measurement?

MR BOULTON: That is the one that I'm talking about, it preferable if you 40 can measure it. So then the activity in the becquerels per gram, that's actually calculated from those parts per million and the quantity of material in the package. Those numbers will change if you had a sample or a drum; that would change slightly. Then we come down to the weighted average of the uranium and thorium at the head of the chain in becquerels per gram and your 45 transport exemption factor.

.SA Nuclear 17.11.15 P-1256 Spark and Cannon

MR JACOBI: Am I right in understanding that that's simply a tool to allow you to calculate the aggregate radioactivity of what it is that you're transporting? 5 MR BOULTON: Yes.

MR JACOBI: In terms of what those calculations then lead you to, can you explain what that leads us to in terms of what's shown on the right-hand part of 10 that table.

MR BOULTON: At the bottom we've worked out that the material - in this case it's low-specific activity material under the conditions of paragraph 409 of the Transport Code. It's above one becquerel per gram so it's considered to be 15 radioactive.

MR JACOBI: The effect of that, as I understand it, leads to a categorisation that it becomes a Class 7. Is that right?

20 MR BOULTON: Yes. Well, the fact there's radioactivity, yes, it's Class 7.

MR JACOBI: Then in terms of the tool, we then see a transport index which shows us a number of 11.2. Can you explain to us just in practical terms what that means. 25 MR BOULTON: I mentioned before the transport index is a figure that is used to help work out segregation and it will also tell you whether the package calls for exclusive use. Exclusive use is where a single shipper will ship his product and give instructions to people how to ship the material. 30 MR JACOBI: I'm just interested to understand, we're looking at a particular tool that's used for the purpose of making a decision. Is that right?

MR BOULTON: This is just a spreadsheet that I put together. 35 MR JACOBI: Is something similar conducted with respect to all shipments? Is that the way that the analysis is undertaken?

MR BOULTON: That's the way I do it. I think people need to do this in some 40 manner or form. People will ring up and say, "Can I ship this material?" and you've got to go back to them and say, "Well, please give me this information so we can make some assessments and get some understanding." Sometimes people are a little bit hesitant because they get confused about commercial-in-confidence. Transport is not about commercial-in-confidence. 45 Commercial-in-confidence is about how much I pay you, who I deal with.

.SA Nuclear 17.11.15 P-1257 Spark and Cannon This is about assessing the product so that I've got an understanding of what I'm actually shipping. Does it really tell you much about what your product is? Maybe that's what people get worried about. But this is important to assess the package. 5 MR JACOBI: Can I come to the next step in terms of the effect that this analysis has on transport planning. I'm just wondering about whether you can explain what's required with respect to transport planning with a good that is identified as being radioactive. 10 MR BOULTON: Just finishing off, this will give you the category of the package: 3 Yellow. So from this, you understand what you're packing and you also understand what the markings, the labels and the placards will be.

15 MR JACOBI: Sorry, what does 3 Yellow mean?

MR BOULTON: There's three categories. So once again in the industrial LSA you're looking at the lowest, which is a 1 White. That's where that accepted package, that small sample, can go in the post. So this is just part of 20 the graded approach.

MR JACOBI: In terms of developing a transport plan, once you've reached a view with respect to these categorisations and these levels of activity, what effect does that have in terms of the need to develop a transport plan? 25 MR BOULTON: I would suggest if you're probably just shipping accepted packages you wouldn't need the sort of detailed transport plan that you would need if you're transporting extremely high-end material. So where you fit in the scale of the material - whether it's low hazard, moderate hazard or high 30 hazard - that will have an effect on the detail of the transport plan. Transport plans are probably something a little bit unique here in Australia, particularly for uranium ore concentrates and material as you go up from that level. I guess they're a good thing. What a transport plan does, it sets out the framework on which you're going to transport this material. 35 MR JACOBI: What sort of information do they include?

MR BOULTON: Initially it will talk about the product that you're shipping; that's the first thing. It will have some detail about what it is you're actually 40 shipping and it will talk about the chemical aspects, the safety, the issues for the public - technical aspects as well. So it will tell you whether this material is explosive, whether it's composition, whether it's liquid form, solid, powder. I just gives you a basic understanding of what it is you're dealing with. Ideally it should contain a copy of your material safety datasheet, which is a technical 45 sheet, so if something goes wrong responders can refer to it. It's important to

.SA Nuclear 17.11.15 P-1258 Spark and Cannon have a copy of that. Then there will be a series of other aspects in your transport plan.

MR JACOBI: Who does the plan apply to? 5 MR BOULTON: It applies to everybody involved in the transport of that material, from packing the material through the whole transport chain. So that will be transporters, road transporters, rail transporters. It will be people at shipping terminals or in transit terminals along the way. So like the Toll NQX 10 up in Darwin, their storage facility before it goes on the train, down at the wharf here and people on the vessel.

MR JACOBI: Does it define their particular obligations as to what it is that they need to do? 15 MR BOULTON: Yes, it will.

MR JACOBI: Is it something that travels with the good?

20 MR BOULTON: The transport plan doesn't travel with the good, no. No, it doesn't travel.

MR JACOBI: But there's something that - - -

25 MR BOULTON: It follows a process.

MR JACOBI: Is it something that's agreed to by each of the parties in the supply chain?

30 MR BOULTON: Yes, they need to understand it and they would normally be given a copy of it. Good practice would suggest that you would do that, provide them with a copy of that. The other thing is, it's overarching - I mean apart from safety, it has security aspects. It has how you monitor the products through the transport chain. It will talk about the particular transport routes 35 that you may use. I've got a whole heap of information in that respect.

MR JACOBI: I will pick them up in detail in a minute when we deal with how a UOC consignment is managed.

40 MR BOULTON: Sure.

MR JACOBI: I just want to deal generally with two other topics. The first is the extent to which incident response is managed at an early stage and whether that's included within the transport plans. 45

.SA Nuclear 17.11.15 P-1259 Spark and Cannon MR BOULTON: Yes, there are details about the incident response, that’ll be spelt out. It’s important with incident response of course - let me step back: you’ve got a number of parties involved in your transport. Normally, the person producing the material isn’t involved in the transport, so you’re sub- 5 contracting, you’re using transporters, you’re using storage people, and they will all have their own incident response plans, if they’re any good. You know, you’re not going to use them if they don’t.

So you have to work within their plan, so it is a bit interesting. So if something 10 happens, who do you respond to, what’s the chain, the hierarchy? The transport plan will spell that out.

MR JACOBI: Yes.

15 MR BOULTON: You know, who goes first? It’s like Abbott and Costello; who goes first, who talks first, who responds, you know? But that’s at the higher level; the immediate level of course, the details in the immediate level will be for those people either on the train or on the truck, or on the ship, on what to do. There’ll be some detail about that. 20 MR JACOBI: Also in general, in terms of the handling of radioactive goods, what’s the extent of the obligation to specifically train those that are involved in the handling of those goods, with respect to their, I guess, hazards or dangers? 25 MR BOULTON: Well, I mean, there’s two parts to that. There’s obviously the company, the transporter, the producer, the shipping line, they have their internal obligations. But overarching that, the IMO have requirements to the INDG Code that state that people involved in the handling, packaging, 30 transport and various aspects of transporting radioactive material will have a level of training as specified in the code by the IMO.

MR JACOBI: Are there particular criteria or elements that are required to be fulfilled for people to be acceptable to actually carry out that work? Are there 35 particular modules in that training?

MR BOULTON: Yes, there are, yes. The IMO has got a very good online program that you can work through, step through, and it’s got quite a number of modules and probably takes, you know, I suppose it takes somebody maybe 40 in their spare time, you know, work through. And you can’t pass it until you get it right, it’s one of those, it’s not one of these easy ones, you know?

MR JACOBI: Is that training enforced by the Australian - - -

45 MR BOULTON: Yes, a week’s work I’d say, at least a week’s work to get

.SA Nuclear 17.11.15 P-1260 Spark and Cannon through it.

MR JACOBI: Is that training enforced by an Australian regulator?

5 MR BOULTON: Yes, yes it is. ANSTO will say that you need a plan, you need training for the people involved, because the person who signs off on the multi-modal shipper’s declaration is signing a legal document, saying that everything’s been packed in accordance with the requirements, everything stated there is correct. 10 I mean, the end game in this is to make sure that when we ship the material that the paperwork describes the product and so that when we submit the paperwork, it doesn’t matter if it’s here down at Flinders Ports or some international port, everybody’s going to understand what’s there and it’s going 15 to flow freely.

MR JACOBI: I want to pick up the consignments when we come to deal with the UOC, and I think I might turn to that now. Can we come back to the point of making an assessment, for the purposes of the UOC, a uranium concentrate 20 shipment? Perhaps you can give us a broad idea, I understand you’ve had significant involvement in doing this, about what the characteristics are of the material that you’re there shipping?

MR BOULTON: Okay. Uranium Ore Concentrate is a non-explosive, solid, 25 heavy powder, high density. It won’t burn, it’s non-fissile, so it can’t support a chain reaction. It is a metallic concentrate. The only unique part about it: it’s radioactive, low level radioactive.

MR JACOBI: And in terms of its radioactivity to mass, in comparison to 30 other? Are you able to express a view - - -

MR BOULTON: Sorry?

MR JACOBI: I think you were expressing it in terms of it having low 35 radioactivity; perhaps we’ll deal with the extent to which you can be exposed to radiation from UOC, but in terms of the implications of what you’ve described in terms of its characteristics, I’m just interested to understand what’s the categorisation that emerges, picking up the categorisations that we’ve just talked about? 40 MR BOULTON: Well, once again it’s low-specific activity, LSA-1 material, it’s Category 3 yellow for ore uranium. The transport index will probably be much lower than the figure stated up on the screen there, for uranium. Normally it’s about probably less than 6, much less than 6 overall. 45

.SA Nuclear 17.11.15 P-1261 Spark and Cannon MR JACOBI: Sorry, 6 what?

MR BOULTON: The transport index.

5 MR JACOBI: Right, yes.

MR BOULTON: It’s just a number. The transport index is just a number.

MR JACOBI: I’ve read UOC described as having a low radioactivity to mass 10 ratio, and I’m just interested whether or not - sorry, uranium ore concentrate having a low radioactivity to mass ratio. I’m just interested if you could unpack that a bit?

MR BOULTON: Well, the best way I can describe it, the easiest way in a 15 practical sense is to say the dose rate emanating from a shipping container, you would get between .82 and .83 and mini-Sieverts per hour, which is probably less than what you would get from a chest x-ray. So considering that you are actually getting from that 18 tonnes of material, which is within the drums inside, very low level. 20 MR JACOBI: In terms of the implications for the categorisation in terms of the package, can you explain how that’s been resolved for the industry, as to what the package selection’s been, bearing in mind the view as to the risks?

25 MR BOULTON: You mean in respect to uranium - - -

MR JACOBI: Uranium ore concentrate; I now exclusively want to deal with that.

30 MR BOULTON: Well, traditionally, in fact since they first started moving this stuff, they’ve been using 44 gallon drums, 205 litre steel drums. I suppose if you go back in time, back to when they were moving this stuff around probably in the late-30s early 40s and they were shipping stuff into America, a steel drum was probably a convenient tool, convenient package. 35 Of course, the industry know as much about this material back then, and they were probably shipping much higher grade ores. But they’ve used this particular package; it serves the purpose well. The actual package that we do use today is an improvement on the original 44 gallon drum, it’s a heavier 40 gauge material, it’s got a better lid, it’s got better where the actual barrel meets the base it’s got a double crimp, all beefing the package up so that its containment is better, it’s got better characteristics.

MR JACOBI: In terms of the ability of the radiation from the uranium 45 concentrate to penetrate the drum, I’m just wondering whether you’ve got an

.SA Nuclear 17.11.15 P-1262 Spark and Cannon observation in terms of its ability to either absorb some of the radiation that’s emitted, and the extent to which measurements are made outside drums.

MR BOULTON: It’s gamma, so it will go through the steel, it can quite easily 5 go through the steel, so you would get a little bit higher dose standing next to a drum than you would standing next to a shipping container, because in the shipping container, you’ve got the steel plate on the wall. However, in a shipping container, you do have a larger mass.

10 MR JACOBI: In terms of shipments, and I think we’ve come back to the question earlier in terms of making actual measurements of the radiation. Are you able to offer some information with respect to the extent to which you’ve made measurements around drums or shipping containers, of what the exposures to radiation are, as they’ve been measured? 15 MR BOULTON: It’s a little tricky if you’re trying to take an accurate measurement of a drum in a packaging plan, because in a packaging plant you’ve got a lot of radiation. You’ve been overseas and probably people have spoken to this: even when you put those drums inside a shipping container and 20 you’ve got a yard full of shipping containers, you’ve got this yard full, there are still other competing if you like, competing activity.

The best place to take your reading is after you’ve put it on the truck, and you’re away from, so you’re well within the limits of normal background 25 radiation, good practice to do that.

As I said before about the activity, that you should take the reading rather than just try to calculate the reading. Anybody setting up a uranium mine should do this. Anybody doing packages should do this. At Olympic Dam, I know that 30 we did it for the first 20-odd years. So you develop a database which you can start to have some - if somebody says, "Do you do this?" and you say, "Yes, and here's the results." It never varies. It's like Craven A cigarettes, they never vary. The results won't change because it's physical and it can't change but you can prove it, you can demonstrate it because you've taken the readings. It's 35 important to do that.

MR JACOBI: I just want to deal with how a consignment overall is managed, and I think we've got some slides that pick up the steps that have been prepared in advance and perhaps if you can take us through the steps from the point at 40 which you're actually at the plant I think you were just describing.

MR BOULTON: The first thing I'd say is that in the case of uranium ore concentrate is perpetually in motion. This material is being produced and being shipped on a regular basis. People don't produce this material to store it. 45 They want to sell it. They're running a business. So you've normally got

.SA Nuclear 17.11.15 P-1263 Spark and Cannon continuous bookings, so you've got a shipping line and you've got bookings. But we start out - as the material is produced, it needs to go through a fuelling plant. Here's an example of - this is the automated plant at Olympic Dam, so empty drums - the first slide is pictorial but the operator has got - and it's 5 showing the batches and the drums. Empty drums are coming in. It goes into the booth itself where automatically the lid is taken off, the drum fuel head comes down and slowly fills the drum with a preset amount of material. As it's doing that, it's taking some samples. Once it's full, it comes out, it's washed, it's dried and it's weighed. Those numbers are then put within a computer 10 system. The middle row you can see the washing there. The second slide in, that's where they're washing it, then drying it. The operator is checking the lid.

Now, the fact that the operator has got that white protective suit, that's just in case he needs to go into the packing booth. He normally wouldn't go into the 15 packing booth. The only reason he'd go into the packing booth would be take the sample carousel out when he's finished or if there was an issue. So they don't normally go into the plant.

MR JACOBI: Could you explain what are the tasks that are performed for the 20 purposes of an inspection. As I understand, an inspection is being performed at this point. You talked about checking the lid. Is there an inspection for any other purpose?

MR BOULTON: Afterwards, yes, there is. 25 MR JACOBI: What's it being inspected for?

MR BOULTON: He marks the drum. There's the drum. He's marked the drum. That last picture on the bottom line - the second-last picture, he's 30 weighing the sample jar. That sample jar goes off to the laboratory for analysis and that's going to help form - there's two parts to that and there's a couple of samples. There's not just one sample jar. Samples are used to check the process, the production process, to make sure you've got no hiccups. Because if you're not making quality product it's going to hurt your price and it shows 35 problems in your plant. So eventually he's just moving those drums onto a pallet and they will be moved within the shed, ready to go into a shipping container.

MR JACOBI: You mentioned that there was an inspection for checking the 40 lids and I'm just interested to - - -

MR BOULTON: He's just making sure that it's sealed.

MR JACOBI: Are there other inspections that are undertaken at this point? 45

.SA Nuclear 17.11.15 P-1264 Spark and Cannon MR BOULTON: After, yes, there are. Before - - -

MR JACOBI: Yes?

5 MR BOULTON: Yes.

MR JACOBI: And what are they?

MR BOULTON: Check the container before - actually before this, we'd check 10 the drum to make sure the drum didn't have any rust in it. Before the drum went into the fuel plant, we've done some pre-checks. Now it's packed, it's ready to go. So the operator then, he will have done an initial check on the shipping container first to make sure that there's no holes in the container, that the shipping container has got its ACA standards so it's accredited so it's fine to 15 ship; that there's no nails on the floor, that there's no - - -

MR JACOBI: Can I just pick up the container itself because I think we picked up the idea here that we're dealing with a package within a package and I'm just interested to the extent to which the container itself is modified for the 20 purposes of transporting drums in terms of flooring or walling that's inserted in the container.

MR BOULTON: No, look, they're general purpose containers, just standard 20-footers. The only thing that we do like the shipping line to provide us with 25 is four or five lugs at the top and the bottom of the container wall so we can hang droppers from which to strap the drums in and contain them. That's the only requirement. We don't like steel floors because you get a good coefficient in friction so the drums will skate around. Metal on metal is not good. So we won't use metal floors but we want good timber floors. We actually use 30 30-tonne rated boxes because the floor spacing is closer. So if there is a failure of the floor, the drum can't slip between the rafters.

MR JACOBI: I think we're at the point of loading them into the containers. I'm just interested in whether you can explain the steps at the point in terms of 35 both their loading and then in terms of their inspection.

MR BOULTON: The containers are preset. There's a plastic liner tray put in heavy duty Forticon plastic put in the base of the container. It comes up the wall about 18 inches. That's basically there - if there is a spill, that will help 40 contain the material so that it doesn't go into the flooring.

MR JACOBI: That's specific to this kind of transport?

MR BOULTON: Yes. It's good practice. I mean the worst thing you want is 45 to have a spill where the material gets ground into the floor and then you've got

.SA Nuclear 17.11.15 P-1265 Spark and Cannon to clean the container or get around to clean-up of the container at a later stage, at the end of the journey. So then the drums are then loaded into the shipping container in a set configuration, and the operator has been trained and knows how to do that. That configuration has been approved by the Australian 5 Maritime Safety Authority.

MR JACOBI: I think we might have a slide that picks that up in terms of - if we step a couple of steps through and I'll come back to the consignments in a minute. 10 MR BOULTON: Yes, go forward a few. So you can see on the first some droppers. Do you see those droppers? There's rings on the top and the bottom of the container sidewall and then we're using horizontal strapping to hug the drums and hold them in. So there's a configuration and the operator just 15 methodically goes through loading the appropriate drums into the shipping container.

MR JACOBI: I'm just interested to pick up the extent to which the independent inspection gets carried out at this point and the purposes. 20 MR BOULTON: At this stage there's no inspection. The inspection of the container has been completed and this guy is just going about his business. He will pack these containers and an independent person will come along afterwards and inspect them and they'll make sure that the drums in, that the 25 strapping is tight, that the loading of the container conforms with the specification. But that's an independent person. It's better to have somebody independent.

MR JACOBI: Can I just come back to the consignments and I'm just 30 interested to the extent to which - what's the information that's included in the consignment information at this point. Perhaps we'll come back to the previous slide.

MR BOULTON: What you've got here is, this information is the information 35 contained within a particular shipping container. So there's 48 - here we've got seven. What have we got? We've got a number of drums - seven drums. How many batches? I can't see there. Have we got - how many rows? My eyes are not good.

40 MR JACOBI: I think about nine or 10.

MR BOULTON: Yes. And looking at the weight, okay. This would be something like an ISL, a uranium-1 or a Heathcote; they would have about 60 drums in a batch, 60 drums in a shipping container. So nine batches, seven 45 drums. So this is the individual batch, each batch, and the weight of material

.SA Nuclear 17.11.15 P-1266 Spark and Cannon within each drum, adding up to a total net weight of UOC, and then from that you’ve got the weight of the drums, so you add in the gross weight of the drums. You’ve got the percentage of UO4; being an ISL-based product, it’s around the 80 per cent. Not the same as say, an Olympic Dam or a Ranger 5 material, which is more up in the 99 per cent, because they put it in through a calcine, it’s just dried.

So the transport index of the drum and the giga-bequerels activity. So that says you’ve got about 17586.9, or something like it. That’s the total, net, kilograms 10 of UOC, right, and the total net UO4 is 14.804; this is for your - - -

MR JACOBI: Yes.

MR BOULTON: That’s because it’s 84 per cent. These fellows actually 15 don’t carry as much uranium, they don’t get as much bang for their buck.

MR JACOBI: The particular point I wanted to pick up was, there’s a calculation in each case, of each drum, of the transport index associated with that drum? 20 MR BOULTON: Yes.

MR JACOBI: Right. And that is based upon a particular calculation of the Becquerel of activity of what’s contained in that drum, is that right? 25 MR BOULTON: That’s right, yes.

MR JACOBI: I think picking up the next - - -

30 MR BOULTON: So then, this has just come through, so now we’ve got three containers, right? So that green information’s come through from the earlier slide, there’s another couple of containers. Now, we’ve got three containers that have been shipped as a delivery, as a consignment, and the information in green flows through to the multi-modal DG form of each container, whereas 35 the yellow down the bottom, that’s what goes to Safeguards - - -

MR JACOBI: That’s what I wanted to pick up, and that is the extent to which the consignment information is used for purposes other than for what you might regard as just the ordinary transportation of goods. 40 MR BOULTON: That’s where it’s important that you’ve got this information, and you can get it to flow through to your multi-modal Dangerous Goods form, you can get it to your Safeguards transfer form that you send to Industry and Science, and also to ASNO. 45

.SA Nuclear 17.11.15 P-1267 Spark and Cannon MR JACOBI: Yes. I just wondered if you could explain what is the obligation - - -

MR BOULTON: This information also goes through to the consignee. 5 MR JACOBI: Yes. Can I just pick up, what is the obligation to provide information? You talk about providing a yellow for Safeguards transfer; what is the obligation in terms of when that information is required to be provided and what is the information that’s required to be provided? 10 MR BOULTON: I mentioned for perpetuity. So you’ve got bookings coming, and you know that you’re going to send three containers of material on a particular shipment; you might have another that’s got four or five. That information you send to the Safeguards office, and initially, you say you’re 15 shipping five containers, and you give them a rounded weight, a rough weight, based on your estimations, maybe on an 84 per cent grade.

They then start to approve that, they then talk to the overseas country and say, “We have some material we’d like to transfer.” They check out all the 20 safeguards behind it, make sure everything’s fine. In the meantime, you’ve actually packed the material, you’ve now got this information and then you just send the final information, say, “Okay, we are actually sending this amount, this many grams,” if you like, “or kilograms of material, we are shipping to this particular location,” because they’re going to use that later to track through 25 with the IAEA and the Safeguards processes.

MR JACOBI: Is that required to be provided prior to its transportation out of the mine site?

30 MR BOULTON: Normally it would be, yes. By the time you’re trucking, yes, you would have the approval.

MR JACOBI: Now - - -

35 MR BOULTON: Because your approval is not a lengthy, onerous process. Over the years, we’ve managed to streamline that process, you know, because these shipments are happening every fortnight. There’s paperwork continually happening with this.

40 MR JACOBI: Now, I understand you’re also required to obtain an export approval. Is the same information also provided to Customs in order to get an approval to - - -

MR BOULTON: The first part is Industry and Science, because it’s a 45 strategic commodity.

.SA Nuclear 17.11.15 P-1268 Spark and Cannon

MR JACOBI: Yes.

MR BOULTON: So there are parts of that information, that key information 5 that goes to them. They’re also interested in the price that you’re selling it for, and now you’re starting to get into the commercial side. There will be other aspects that they want to know. They really want to know what the free, on board value is, so they can send that to the ABS behind the scenes.

10 But intermingled with all that, so you get the Safeguards approval, the DIS approval, and then that goes to Customs Border Protection, so when you submit your PRA, pre-receipt advice for the boxes to go into the terminal, you’ve actually got your export clearance. But you can’t get the export clearance without the permit, without putting that paperwork in. 15 So that tidies up all the safeguards and export control.

MR JACOBI: Can I just pick up finally, coming back to the container, in terms of the information that’s provided to the shipper: are photographic 20 records or other records maintained of what’s contained within the cargo, other than the consignment note?

MR BOULTON: No. That information you would share with the shipper when you’re bringing the shipper on board, you know? When you go to a 25 shipping line, essentially you need to go to the shipping line and you have to have a conversation with them and bring them on board with the journey. So you’ll give them a presentation, give them all the background and they will understand how it’s packed. They certainly would.

30 MR JACOBI: Right. Now, I’m just interested, we picked up the concept of an independent inspection, that is, independent from the person that in fact packed it. I’m just wondering perhaps whether you could walk us through what that process involves, and who does it?

35 MR BOULTON: Look, container inspections are an important process, and it’s been exacerbated on the slide there by the Convention for Safe Containers, and the US PAT requirements, Protection Against Terrorism. It also addresses the IMDG multi-modal requirements and other obligations.

40 So on the left-hand side there, that’s the guy who’s going to pack the container, or one of his team, and he’s actually checking the container out. So he’s checking to make sure it’s compliant, he’s looking at the compliance plate on the door, he’s also going to check the container floor. He will get the container lifted up in the air so he can look at the undercarriage; he’ll be making sure that 45 there’s no huge dents or that the roof hasn’t got bows in it that can hold water,

.SA Nuclear 17.11.15 P-1269 Spark and Cannon cracks. He’ll actually go inside that shipping container and somebody will shut the door, and when you’re inside a shipping container with the door shut, it’s a little bit daunting, but it’s pitch black. If there’s any light, if there’s a crack both in the rubber door seal, he’ll be able to see that and he’ll reject the 5 container.

Middle slide, that is an independent lady, and she is actually checking that the drums are the drums that were destined to go in there. She’s also checking on the strapping and she’s also having a look around the container to make sure 10 that there are no dents, that he hasn’t missed anything, so she can do a bit of an independent inspection there.

As I’ve always said, particularly when we were moving copper, you know, making sure that nobody’s left anything in there that shouldn’t be there, you 15 know, you don’t want paper or rubbish; you want your product to look fine when they open the doors at the other end.

MR JACOBI: Now, can I just come to the point, leaving the inspection behind - - - 20 MR BOULTON: Just on the final one, you can see, just these yellow items here, they’re container bolt seals. So she’s pre-allocated those, and they will be part of the shipping documentation. Once she's finished, lock the container up, two bolt seals on the container door. 25 MR JACOBI: In fact, that's where I was going to come. In terms of the container at that point is sealed, is it then able to be opened again before it ultimately reaches its destination?

30 MR BOULTON: ASNO do not like their boxes being opened once you've left the mine site. There has been situations where we have, for various purposes. When we went up on the rail, we did that to make sure that the drums hadn't moved. There were some concerns at the time. But normally, no, it doesn't happen. However, we have no control over some efficient supervisor or people 35 say in a port overseas. However, when the containers are overseas we have our overseas agent will have somebody check those boxes and if they have been opened there is a process where we can notify ASNO and put new seals on the boxes. But sometimes people say, "What's in the box?" Now, even though you've got good paperwork and that should prevent that, you'll never prevent it. 40 MR JACOBI: This is inspection by overseas Customs services.

MR BOULTON: Well, it could be Customs, yes.

45 MR JACOBI: I just want to deal with the issue of transportation from the

.SA Nuclear 17.11.15 P-1270 Spark and Cannon mine site to the point of export in terms of - I think we discussed transport planning. Am I right in understanding that there's a standard transport plan for its movement from its location at Olympic Dam to Adelaide?

5 MR BOULTON: Yes, there is. The transport plan has been approved and that sets out the process. So what happens with the movements, it's perpetual, they're ongoing. So normally every month the consignor or the producer sends a notification to the government. It uses a central agency, DPC, Department of Premier and Cabinet. They've always been the one stop shop, if you like. 10 They will say, "Okay, this coming month, on these weeks we plan to move, as per our schedule, so many boxes." That's just a heads-up, if you like, of what's going to happen, rolling over month by month. On the day that the boxes are moving, when the boxes actually physically leave the site there's a notification again goes to the DPC. That will say, "Today is three boxes. These are the 15 container numbers. They left Olympic Dam at" - or, "they left the mine site" - whatever - "at a certain time. They're expect to get where they're going at a certain time." That information the DPC then disseminate to those people who need to know. So it's typically the police, CFS, MFS. There's a range of parties. Then the transport continues. 20 MR JACOBI: I just want to come very, very quickly to at the port itself in terms of its management at that point. I think we've got a slide that picks it up. I'm just interested to understand the extent to which there are obligations with respect to where these particular ISO containers are stored on vessels. 25 MR BOULTON: Maybe even if you step back. I mean when these boxes - I will just step back. During the transport from the mine site, whether it's from up north, coming down by train or from Darwin or wherever, those transports are monitored and within the transport plan it states how you will monitor it. 30 Most of the trucking companies have got sophisticated GPS on the trucks and they can tell if the truck driver is over-accelerating, heavy braking, where he is. That's fine. But normally we just have certain points where the truck driver crawls in and you tick off where he is.

35 When they get to the shipping terminal, just go in in the normal process. There's nothing special for this process. They don't get out with red carpets or blue carpets, waving flags. They just come in like a normal container would come in. The only difference is coming out Olympic Dam they actually use A-doubles all the way into the terminal but there's other operators who use 40 A-doubles. It's then stored within the terminal normally for a week or less. You transport this week, it goes out on next week's ship. So it's stored in a defined area where people at the port know where it is. They need to know.

Then part of the ship's planning is to - and this is just typical of a ship plan. 45 This is universal. So this is just showing - and you've got the longitudinal

.SA Nuclear 17.11.15 P-1271 Spark and Cannon section of the ship and then you've got a cross-section looking along the ship. These are just basically container slots within the ship. We are fortunate here, that we put the material underdeck, up-front in nice little cuddies. So once again you've got additional encapsulation so that it protects the containment of 5 the container. I think I had some pictures somewhere that might show that. I mean this is standard shipping. I guess you're familiar with, Chairman.

It will tell you what kind of - the different colours are where the boxes are going to be unloaded. They use different colours. Then within these other - it 10 tells you what the material is, whether it might be dangerous goods or what is the class of material. They can drill down and in fact they use this material at the - I mean they guys have a permit to possess material at the wharf and the ASNO and the IAEA will come down and go through their paperwork and say, "You've received material from the mine. When did it come in? Show me 15 when it came in, how long it was here," and they can use all of the history from this information to satisfy the requirements.

COMMISSIONER: Is that on an individual basis for every shipment or is that a check? 20 MR BOULTON: Sorry?

COMMISSIONER: This inspection from the IAEA or the - - -

25 MR BOULTON: They're quite random but they will go back and say, "Show me your history for the last six months," and they will follow it through. I was only down there last week talking at the terminal with some people, with somebody who's taking over another mine, and they just openly mentioned, "Yes, we get inspected, we get audited." I mean all of these processes are 30 auditable and audited, and the IAEA, they come in at any time. So this information is standard. There's no secrets. It's all time stamped, every container move, every time it moves.

MR JACOBI: I'm just interested, once the vessel leaves the port, the extent to 35 which the operator or the consignor that's transported the goods monitors their ongoing movement.

MR BOULTON: There's a vessel leaving, a tug coming in. It's monitored all the way. You can see there we leave the mine site, local transport to the point 40 of export on the water - maybe through a transshipment port, back onto the water again, overseas discharge, overseas transport, final destination. So that's a tracking form, an ASO 203 form. The consignor sends that to their overseas line carrier and they will check - you've got depart Australia, transshipment port, second transshipment port (indistinct) final discharge (indistinct) and they 45 will check that.

.SA Nuclear 17.11.15 P-1272 Spark and Cannon

On that form, as I mentioned, if somebody has changed the seal numbers, they will write on that and that form gets sent back to the safeguards. That's part of the safeguard's obligations, to be able to show the IAEA that they're tracking. 5 There's a period of time after the ship sails - I think it's 24 hours after the ship sails - that you will let them know that the ship has sailed and there's some time obligations on this. So it's not a case of, "We'll do it when we feel like it."

MR JACOBI: Who conducts the inspections at those ports? Is that the 10 consignor's agent?

MR BOULTON: Yes.

MR JACOBI: So the consignor's agent is then responsible for transmitting the 15 information back to ASNO. Is that right?

MR BOULTON: Their obligation is to send it back to the consignor but in today's world, with email, normally they will email it to both.

20 MR JACOBI: I just want to pick up the question of incidents that might be involved with UOC transport and I'm just interested to get your view about if there is such a thing as a typical incident involving damage - and I think we've got some slides to pick it up - what your view of those sorts of incidents might be. 25 MR BOULTON: If we talk about safety, there's a graded approach to safety. We have normal, routine and accident conditions. Here's some examples of a bump and scrape. This was a container that had drums of uranium in it and - I forget - this happened probably in America I'd say because it's most likely in 30 America that's where it happened. Somebody has gone along the side there of the container and you can see the scrape on the first slide. You can see the extent of a fairly strong gauge. What happened from there was, at the port, they got a radiation meter, they checked. They were able to look inside, shine a bit of light in, which was well clear of any drums. We spoke by email and I 35 said, "Look, the easiest thing to do is just patch it, patch the hole," which they put a patch on, on the third slide. We've noted it. A note has gone to ASNO and a note has gone to the consignee saying, "This particular container, when it arrives, just check and they will" - and so they're aware - because I guess when they open it, if there is any chance of there being a spill, it's good to give them 40 a heads-up that there. But no spill with this. No damage.

MR JACOBI: I'm interested to get your perspective, I gather you've followed UOC shipments over the course of your career. I understand there's a concept of a reportable incident. Perhaps you can explain what that is first. Any 45 incident that really loses control of the process - processes are in control while

.SA Nuclear 17.11.15 P-1273 Spark and Cannon they're moving along. Once somebody stops anything, you lose control of the process, it can be reportable. I mean some of the incidents - this would border on being reportable but I would report that to ASNO because I think it's best that they know and it also shows them that you can manage. 5 Higher end might be more significant damage than that. I think we've got another slide that might show a little bit more significant damage. So this one here, that was certainly reportable. This happened in Vancouver a couple of years ago. The container has been struck by something. I'm not sure but you 10 can make your own mind up about it. There's a drum sitting in the corner of the shipping container there. Now, this actually triggered the incident response in Canada with Transport Canada. Cameco are the responder and Cameco responded to this accident. There's the container. There's a guy just got his dust mask on and he's going to hope into the container and have a look. So 15 there's the drum in the corner, in the middle. There's the bulge in the container wall and then you can see the damage on the drum. What it shows is that there is strength in the packaging.

MR JACOBI: I'm actually interested to understand was there a failure in the 20 packaging?

MR BOULTON: No, no failure of the packaging. No contents were released. So it shows that these drums are fairly strong. If you think back to that picture, it's been hit by something pretty damn hard to bend that container wall like 25 that. So the container wasn't fit to transport; it only had three pegs. A bent peg you couldn't lock down on a truck. So we organised a fresh container and the drums were repacked and that particular damaged drum was placed in the yellow overpack and shipped off to the consignor. But that's probably more than a normal incident, but that was certainly reported and the reporting - 30 people in the industry know what to do. They know to report. It happens. That really is a reportable incident that one.

MR JACOBI: I'm just interested to understand the number of reportable shipments given the movements that have occurred around the world of 35 uranium concentrate over the last several decades. How many reportable incidents there have been and what was their nature?

MR BOULTON: I don't know what the total number is world-wide but I know out of the - what I'm aware of and it's a figure less than 10. The reason I 40 know that is because they're so few and far between in all the years that I've been doing it and I always remember them.

COMMISSIONER: How many years, Frank, have you been doing this?

45 MR BOULTON: We started in 1988 and I finished in 2012 full-time, so

.SA Nuclear 17.11.15 P-1274 Spark and Cannon 24 years.

COMMISSIONER: So 10 incidents in those - - -

5 MR BOULTON: 10 incidents, yes. A lot of those were just bumps and shunts. There was a piracy incident in the Gulf of Aden. That was a significant reportable. The carrier, bang, straight off to ASNO with a report. Steven Smith jumped in, you know. Things happen. So there's a process and that's fine. I got a bit annoyed because we couldn't ship through that way any 10 more but I understood why: piracy is a concern. But, honestly, in percentage terms very, very low. I think it just shows that the transport of radioactive material as a daily occurrence is well managed.

COMMISSIONER: In your experience, has there been an escape of the 15 product from the package?

MR BOULTON: Yes. One of the incidents in the very, very early days when we used to secure the drums within a shipping container using timber, which was the original process, one of the drums had actually moved and had worn 20 the bottom lip away. It must have done a lot of vibrating. Going back then, those containers were on the top deck of charter vessels when started moving - - -

COMMISSIONER: It can get bumpy at sea. 25 MR BOULTON: It can get bumpy at sea, that's right, and they danced. The method we use now hugs them a lot tighter and allows it to move, whereas timber doesn't, and then the drum. So, yes, that caused a release of contents. So through that we then went back and what the industry does is it learns from 30 its lessons. So we back to the drum manufacturer and did the double crimp, an extra crimp. In 2002, that's when I started to look at - and I got away from the timber and started to use this better method. I think it's a better method because the drums, with the Kevlar webbing, can actually move, whereas timber just doesn't. You put a wedge in the timber and the container moves 35 and the wedge falls out.

COMMISSIONER: What about in the road transport from Olympic Dam down to the port? I mean that's been going on since the 80s. You must have had accidents, I would have thought. 40 MR BOULTON: The only one that I can tell you about that occurred was just a traffic incident where a truck basically chopped in front of an A-double - a B-double jumped in front of an A-double and there was a slight dint, just a scrape on the truck. I think the B-double probably came off worse. But once 45 again, I was in the office about 4.30 on an afternoon, got the call. The truck

.SA Nuclear 17.11.15 P-1275 Spark and Cannon was out at Linfox at Port Adelaide and I went out there, had a look and I appreciated what they did. They asked me to come out and have a look. They had it under control. They knew it but they asked me to come out. That was a reportable one. So very, very minuscule. 5 COMMISSIONER: In terms of transporting other radioactive material other than uranium oxide, have you been involved in something more potent?

MR BOULTON: Probably a little bit of radium. 10 COMMISSIONER: Mostly uranium oxide.

MR BOULTON: But mainly uranium oxide. But the processes, the procedures, using the graded approach, it will work. If you look at lower grade 15 material, the accepted package IP1, the hexafluoride special package or hexafluoride missile materials, the Type A, the medium hazard, up to the B. The processes that you apply to transport, you just scale them up. You use that scalable process. I think later in the day other people will reinforce that point.

20 MR JACOBI: I'm just interested in perhaps one last thing in terms of if there was an incident, is it necessary to return the package back to Roxbury Downs or is that a possible option in terms of repacking, if that's a necessary step?

MR BOULTON: Yes, that is the process, you would take it back. You 25 wouldn't ship it. I mean in this particular instance it was basically as close to being on the doorstep - I mean it was in Vancouver and it's heading off to Ontario, so it's a retake. But if it was here, they would take it back, yes.

MR JACOBI: And has that been necessary as a step if there's been difficulties 30 in terms of things not occurring as expected, in your experience?

MR BOULTON: It may have happened once. In fact, it has happened once, yes.

35 MR JACOBI: What was the nature of that?

MR BOULTON: There was a bump and a scrape and the decision was made to take some material back to site, yes, for repack, but I wasn't there.

40 MR JACOBI: Did that involve a release of any of the contents?

MR BOULTON: I'm not sure. Look, I don't know. I haven't really seen any final reports but I do believe that that matter will be discussed at WNTI in December. 45

.SA Nuclear 17.11.15 P-1276 Spark and Cannon COMMISSIONER: Mr Boulton, thank you very much for your evidence, participating and also for the preparation that you've made to help us understand the transport of nuclear materials. It's very much appreciated.

5 MR BOULTON: Thank you, Kevin. Thank everybody.

COMMISSIONER: We will adjourn now until 1200.

ADJOURNED [10.12 am] 10 RESUMED [11.59 am]

COMMISSIONER: We will reconvene topic 14, the transportation of nuclear materials. We very warmly welcome from ARPANSA Mr Jack Dillich and 15 Dr Samir Sarkar. Counsel.

MR JACOBI: ARPANSA is the Commonwealth government's authority on radiation protection and nuclear safety. Its functions are multifaceted and include the promotion of radiation protection standards that are consistent 20 across Australian jurisdictions and in line with international best practice, including those applicable to the transportation of nuclear and radioactive materials. Mr Jack Dillich has been the chief inspector and head of regulatory branches 2014 and is responsible for licensing, compliance and inspection of all Commonwealth entities using radioactive sources and operation nuclear or 25 radiation facilities. Mr Dillich is a nuclear engineer and has worked for decades in the commercial nuclear power, nuclear propulsion and research sectors.

Having joined ARPANSA in 1999, Dr Samir Sarkar is currently a principal 30 inspector in the regularly services branch. He holds a PHD in nuclear science from Kanazawa University in Japan, and his areas of expertise include nuclear fuel management, radioactive waste management, and the transportation of radioactive materials. Dr Sarkar is the Australian representative of the IAEA's transport safety standard committee. The commission calls Dr Samir Sarkar 35 and Mr Dillich.

COMMISSIONER: Gentlemen, thank you for joining us. Can I start with a description of the various packages, and perhaps starting with accepted packages, so I want to try and get an understanding of the contents, the form of 40 packaging, the design characteristics, and the expected radiation levels from each of the packages. We might just move through them one by one if that's okay. So start with accepted.

MR DILLICH: Slide 3, please. Very good. Now, in order to set the table, I'm 45 going to have to back up just a little bit, but give me a couple of minutes to do

.SA Nuclear 17.11.15 P-1277 Spark and Cannon that. First of all, radioactive material is shipped around the world. Millions of consignments happen every year around the world. It's been going on for decades and the track record of the industry is quite safe. Before we delve into the package types - and this slide shows all five types that I'd like to talk about 5 - I need to talk a little bit about radiation and radiation dose, because we're talking about radioactive material, which is a dangerous good class 7. There are many types of dangerous goods which are shipped around the world. Class 7 is one small fraction of those.

10 The radioactive material that's being shipped does present a radiation hazard to people in the environment. The packages are meant to allow the shipment of these, either by sea, by air, by rail or by truck, safely. All living organisms are exposed to ionising radiation every day. You and I are. This is natural, it comes from food, air, and cosmic rays. Typically an individual will be 15 exposed and receive anywhere from two to three thousand microsieverts per year in radiation. That's year after year. This is natural and it's what we are.

A return flight - I want to put this into context, because we're going to talk about radiation dose, I want to put it in context. The radiation dose you would 20 receive just by a flight, let's say from Australia to Europe, or to the United States and back, a return flight, would be on the order of 100 microsieverts. So you would receive an additional 100 microsieverts for that holiday that you take, as a result of just being up at 30,000 feet for 10, 15 hours, something like that. That's ballpark. Now, science tells us, we've studied this quite a bit, that 25 the effect on the human body at this additional 100 microsieverts is insignificant. It's negligible. It's not even measurable. That's true by probably three orders of magnitude. So it's very, very insignificant, that 100 microsieverts. So I'll try to put that in the context when I talk about each one of these packages. 30 The accepted packages are packages which are used to transport radioactive material that is of such a low level that the potential hazard is insignificant. Generally for accepted packages, although they are labelled appropriately, there is no testing that's involved, and you can see it's basically the box with 35 the "fragile" on it, there will be something that is just very, very slightly radioactive. There's no shielding involved, there's no cooling involved, and if you were to hold that package for hour upon hour, the total dose would be less than the insignificant amount that I talked about of 100 microsieverts.

40 COMMISSIONER: Is there in fact a limit at the surface for an accepted package?

MR DILLICH: Yes, there is.

45 COMMISSIONER: What's that?

.SA Nuclear 17.11.15 P-1278 Spark and Cannon

DR SARKAR: Five microsieverts per hour.

MR DILLICH: So if you were to stand there and hold it for 20 hours, and it 5 was at the limit, which is highly unlikely, you would receive that insignificant dose that we would all accept. By the way, a chest x-ray is about the same, 100 microsieverts. I give that as an example because it's something we accept in society. Accepted packages may be used for limited quantities of radioactive material and the potential hazard is just not there. 10 Let's get into industrial packages. They're typically used for two types of material. One type of material is a material that has a very low specific activity. What that means is the radioactivity per unit mass is low. The other type of material that it's used for is material that would have surface 15 contamination. A good example of that would be tools that are used at power stations. Instead of generating a lot of low-level waste trying to decontaminate these tools when they're just going to be contaminated again at the next point of use, they would be transported, for instance, as an industrial package.

20 Industrial packages are subdivided into IP1 through 3, which differ regarding the degree to which they're required to withstand routine and normal conditions of transport. They're used for low-activity materials such as uranium oxide concentrate. I'm pretty sure you've had experts in here talking about uranium oxide and the transport of that. That would not be unreasonable, to have a 25 container like that full of 200-litre drums of that kind of material. Low specific activity.

MR JACOBI: Again, to pick up the question from before, is there a limit that's specified with respect to exposure - - - 30 MR DILLICH: It's the same one.

MR JACOBI: It's the same. It's fine.

35 MR DILLICH: Typically that's a limit and it's not approached in any fashion.

MR JACOBI: Actually, could I pick up on that. In terms of measurements, to what extent are measurements made with respect to such packages? You're saying that you're not going to receive a rate of - - - 40 MR DILLICH: The point of origin has the responsibility for measuring, and typically when it's done, it's done with a radiation instrument, a handheld radiation instrument, and it will be measured on contact, which is typically a couple of centimetres up - the probe will be a couple of centimetres away from 45 that, at various locations, a full survey. The external part of that particular

.SA Nuclear 17.11.15 P-1279 Spark and Cannon container would also be smear-surveyed to make sure there's no loose surface contamination as well. Then at one metre is the typical location. So at various locations a metre away from the outside of that, it will be taken.

5 MR JACOBI: So is the five microsieverts as at the surface, or is the five microsieverts per hour, is that the - - -

DR SARKAR: From the industrial packages, you can go up to even 500 microsieverts. However, in practice it is not the case, because what they 10 consider is, if you work in that industry, so package handler, whatever it is, considering that you may want eight hours a day, the total effective dose throughout the year that a human within the public limit - that is one millisievert per year, even if you are - throughout your lives. So that's the limit there. Also there is (indistinct) transport index. So you have to comply with 15 that one, which is a requirement, that you have to record that for this shipment, transport index, based on your particular measurement (indistinct) the surface of the package.

MR DILLICH: Okay. In general, low-level waste - and by the way, I digress 20 again, but I have to set the table. We talk about low-level waste, intermediate-level waste and high-level waste, and those waste categorisations are not based on transport. Those are for storage of wastes, okay? We talk about them in the terms of transport just because they're classified that way ultimately one way or another. For transport it's all about the radioactivity, and 25 to some extent the form, and almost all of this is in solid form. Okay? For accepted and industrial package types, shielding is not a particular issue. However, you can see that the metal associated with that container right there will provide a certain amount of shielding. Distance is also important. So you mention on surface, and the further away, of course, from the point source, the 30 dose rate will drop off exponentially, so quite a bit.

Type A packages are used for the transport of relatively small but significant quantities of radioactive material. Now, because it's assumed that this package could be damaged in an accident, a severe accident in particular, and that the 35 portion of the contents may be released, the amount of radioactivity in a type A package is limited. It's a very complicated formula because it depends on the radionuclides involved. So you look at all the radionuclides after it's been characterised and you kind of sum those up into a total. In the event of a release of a type A package, these limits ensure that the risk from external 40 radiation or contamination are very low.

MR JACOBI: I think that slide might pick up some examples of those.

MR DILLICH: Here's a very commonly used type A package, in Australia as 45 well it's being used, and this is a technetium generator. Maybe you can't see it.

.SA Nuclear 17.11.15 P-1280 Spark and Cannon The cutaway is meant to show how the source, the generator itself, is inside this rather large, well packaged unit. It's my understanding that the packages are reused so the customers - there's probably a hundred customers Australia wide - in this particular case, if it's Gentech generator like the bottom picture 5 shows, ANSTO would be sending these out routinely every week of the year and the packages would come back and be reused.

The packages also have a certain amount of shielding, so one of the points I wanted to make with a type A package is there is shielding. It depends on the 10 source, but typically if it's a gamma source, which is the predominant source of concern for external radiation dose, there would be either metal or lead. Those are extremely effective shielding materials. This is a type A packages. Now, type A packages, unlike the other two we discussed, are in packages designed for certain expected kind of accidents. 15 In this particular case, it could be used on an aeroplane or it could be use on a truck. Well, it's probably used on both. This particular material, the generator itself, it's very perishable, it has a very short half-life, so it has to be transported rather quickly to the point of use. 20 MR JACOBI: As I've understood the evidence so far, there's an adjustment of the material that's included and the shielding. As against what standard is that adjustment made in terms of, again, the expected radiation dose on the outside of the package? 25 DR SAKAR: Yes, it is a requirement of the type A package that you have to amend within a certain limit, the transport index is, again, control factor.

MR JACOBI: I understand the transport index is the control factor, but, again, 30 perhaps to bring it back to very practical terms, we've talked about a limit of 5 microsieverts per hour. Is that the same limit that is again applied?

DR SAKAR: No, for this one you can expect normally 14, 15 microsieverts per hour from one of the generator. This is the extreme case, big case, as you 35 can see.

MR DILLICH: The way it practically works, if you have radioactive material that you have to get from point A to point B, you're not going to create and certify a package of that, there are going to be packages available that are 40 certified for use, so you have to make - typically, it's a commercial decision, "How do I get it there?" If you can, you split it up into small pieces and you ship it a number of times, you make a number of shipments to get it where you want to go. We haven't got into type B packages yet. Type B packages can be extremely expenses, so you don't want to use a type B package for something 45 that could be done much cheaper.

.SA Nuclear 17.11.15 P-1281 Spark and Cannon

MR JACOBI: One of the methodologies might be to simply divide so as to reduce the amount of activity you get from that source, and that then meets your controlled external limit. Is that right? 5 M DILLICH: Correct.

MR JACOBI: Right.

10 MR DILLICH: In this particular case, staying with this example, I think the biggest generator that ANSTO puts out is 370 gigabecqurels, which is about 10 curies, and so that's as strong as the source is going to be, and their packages are designed such that the radiation doses that somebody might receive under normal transit conditions or whatever would be insignificant. We can do the 15 same thing after a couple minutes here, we can go to slide B. Type B packages are required for transport of highly radioactive material, and typically when we hear about highly radioactive material we might think of spent nuclear fuel from a commercial reactor.

20 That would be the prototypical classic type B package that's used. These packages are tested, they must withstand the same normal transport conditions as type A, but because their contents are much more than the type A it's necessary to specify additional resistance to release radiation or radioactivity. The concept is that this type of package must be capable of withstanding 25 expected accidents, and expected means reasonable accidents that could occur. Type B packages are used to transport material that's different, as spent nuclear fuel to vitrified high level waste.

They're used for shipping larger quantities, as I mentioned before. There are 30 many, many kinds, probably 150 certified designs around the world, and some of the more expensive ones cost over a million dollars. Before we leave today, we will talk about one that we have experience in licensing. Type B packages use shielding to limit the dose rate, they have to, and so you can see the Type B package at the bottom there. That is probably four metres, five metres high, it's 35 extremely large. There's another picture with an individual standing and you can see how small he is next to it.

There you go, in the lower right-hand corner. That is just the outside of the package, there's quite a bit of steel. Something like that might weight 40 100 tonnes empty, and then another six or eight tons with, let's say, spent fuel inside. These things are massive, they're not going anywhere. The amount of steel, there's lead lining as well, so the shielding is quite significant. Type B packages, I'll get into this in just a second, but when we're talking about irradiated spent fuel, because the radiation, the decay heat, the residual heat 45 from the fuel is still such that it puts off heat, there's a cooling period and the

.SA Nuclear 17.11.15 P-1282 Spark and Cannon fuel is typically either in water or stored onsite for months, if not, years, before it's actually shipped, so by the time it's shipped not only the radiation but the heat that's being generated has decayed away quite a bit.

5 Let's go to slide 4, if we can. Type C, I don't really have a lot to say about type C because I have no practical experience with type C. Type C packages came about around the time of the 1996 addition of the International Atomic Energy Agency transport regulations. They introduced this type C for a very, very robust design for air transport. Smaller quantities of high activity material 10 can be transported in type C packages, these packages are most robust, they're designed to survive sort of like a black box, if you will, being dropped from an aircraft. It's pretty robust.

It's my understanding, and this is not first-hand experience, that the Russians 15 have some experience with type C packages. They have transported spent fuel and new fuel by air. Can we go to, maybe, slide 6? There you go. Very, very quickly. I talked about radioactive material, but 95 per cent of what is shipped as radioactive material has nothing to do with the nuclear fuel cycle, you didn't invite me here to talk about the 95 per cent, so let me focus just for a little bit 20 on the front end and the back end of the nuclear fuel cycle and kind of focus on maybe the 5 per cent of radioactive material shipments that would be of interest there.

In terms of yellow cake, uranium oxide concentrate, that's transported from the 25 mines to conversion facilities, they're typically in 55 gallon, 200 litre drums, if you will, into shipping containers. There's no special radiation shielding required, the yellow cake is only slightly radioactive, but typically it's alpha, an alpha emitter, and it can be stopped very easily with any type of substance whatsoever. UF6, uranium hexafluoride, nuclear fuel is transported to and 30 from enrichment facilities in the form of this uranium hexafluoride.

It's chemically toxic, but it's still only slightly radioactive. It's typically shipped in cylinders such as the one on the upper right-hand corner, and these cylinders are rather large, they're a little over a metre in diameter typically, 35 depending on the enrichment. For commercial nuclear fuel, the uranium is enriched maybe 4 per cent, typically.

MR JACOBI: Can I just interrupt you just at the level of the hexafluoride, the gas canisters there. What category are we dealing with there? Are we still at 40 the stage of industrial packages as we were with respect to uranium ore concentrate?

MR DILLICH: I've moved beyond the industrial packages. No, it wouldn't be industrial in this particular case. 45

.SA Nuclear 17.11.15 P-1283 Spark and Cannon MR JACOBI: Right.

MR DILLICH: It becomes a little bit more complicated. Once you're dealing with fissile material, there are additional requirements associated with fissile 5 material above and beyond just normal radioactive material.

MR JACOBI: No, I'm just dealing with the issue of the material at the point of conversion, and so what I'm interested in is to understand at that point - - -

10 MR DILLICH: Okay, yes, the front end with the conversion for - - -

MR JACOBI: Before we get to enrichment.

MR DILLICH: UF6, in that particular case, that might be industrial. 15 DR SAKAR: Similar to industrial, similar to it, it does not need any approval.

MR DILLICH: I got ahead of myself. Thanks for that. Yes, I don't need to talk about that. In this particular case, yes, and there are a number of different 20 cylinder designs that can be used for that kind of transportation, so no cooling required, no shielding required there. New fuel: if you have new fuel which has been fabricated for use in a nuclear reactor somewhere, it's going to look like this whether it's been irradiated or not. But here, again there's no shielding required. New fuel is not particularly radioactive. You can handle it. So new 25 fuel is fairly easy to transport as well. The most common means of transporting new fuel is by truck, rail, but it could be also by sea or by air. The biggest thing with new fuel is it's expensive and the tolerances are extremely important. So it's handled very gently and it has to be packaged so that it's not damaged during transport. 30 MR JACOBI: Can I just pick up the point of new fuel and then to the point of the converted materials. If you were to approach it from the perspective of what the radiation exposure you might reasonably be expected to be, again is there a design limit in terms of the way that the casks or the containers are 35 designed in order to provide a particular outcome in terms of radiation exposure at the surface?

DR SARKAR: Exposure is not the main issue here. The main issue here is more of protecting the fuel plus the criticality. So these are the key aspects. In 40 terms of (indistinct) it will be background level.

MR DILLICH: So the uranium is like hexafluoride, from a chemical point of view it is toxic so you need to be concerned about that. But from a radioactive point of view, none of this would be of any concern. If we go then to the back 45 end, the next slide we see, now it gets a little bit more interesting. So on the

.SA Nuclear 17.11.15 P-1284 Spark and Cannon back end, when fuel is unloaded from a reactor core typically instead of having a hundred per cent uranium in some kind of form or whatever, it's been in a reactor core for, let's say, five years - three cycles or something like that. It's highly radioactive. It's typically contained still predominantly 96 per cent 5 uranium. You now have about 1 per cent plutonium which has been transmuted as a result of being in the reactor for so long. Then these nasty 3 per cent fission products which are highly radioactive. So that's good.

Now, what you see here in these pictures - and I just wanted to give you a 10 flavour for it - in the United States where most of my commercial experience is, because there's not a solution to what to do with the spent fuel, all hundred reactors at the many different sites still have the spent fuel from the original core load. So what they do is, they typically will put it in spent storage pools under water and they'll keep it there for a couple of years. But more and more 15 what they're doing is, they're using these dual-purpose casks. These are Type B packages. You're looking at the outside, which is concrete, but there's a lot of metal inside those things. What they do is, they simply store - and these are licensed facilities, spent fuel storage facilities - these are licensed facilities where spent fuel is passively stored, shielded and, through natural 20 convection, cooled.

The fuel, for instance, inside of these - you can see the worker standing right next to it - there's enough shielding there that there is no significant dose one way or the other. They're typically inside protected areas, just like the reactors 25 themselves. They're typically adjacent to the reactors. That is just a practical solution because there's still no political solution in the United States for what to do with this.

I bring this up just because it's a pretty good case in point: there's a number of 30 ways to safely store high-level waste, and this is an example of that right there. The cask in transport on the upper right is another example of a Type B container. This would be highly radioactive, but you don't know exactly what's in it and I don't have it in my notes right here but you can see it's being transported on a railcar from one point to another. 35 The drums down below, again when I talk about transport packages, it doesn't matter what the material is going to be used for or what it was used for. It all has to do with radioactivity and the form it takes. So in this particular case it's possible that you could have waste where the total amount of radioactivity in 40 the radionuclides would require it to be transported in a Class A or a Class B container. This is a typical drum of radioactive material that would have to be done in that fashion.

MR JACOBI: Can I pick up there. The commission is interested to 45 understand the record associated with - we understand the spent fuel has been

.SA Nuclear 17.11.15 P-1285 Spark and Cannon moved and we're interested to understand the record in terms of the movement of spent fuel and whether there's been any manifestation of risk associated with this movement.

5 MR DILLICH: I do have some statistics here. I'll go through them rather quickly. Since 1971 there have been 700 shipments of used or spent fuel over many millions of kilometres with no property damage or personal injury, no breach of containment and very low dose rate to the personnel involved. This includes 40,000 of used fuel shipped to AREVA's La Hague reprocessing 10 plant. At least 30,000 tonnes of mostly UK-used fuel shipped to the Sellafield reprocessing plant and 7000 tonnes used fuel in over 160 shipments from Japan to Europe by sea. To some extent I think 4500 tonnes of used fuel around the Swedish coast. Some 300 sea voyages have been made carrying used nuclear fuel or separated high-level waste over a distance of more than 15 8 million kilometres. We're talking about 4000 casks, each of about a thousand tonnes.

So this has been going on for decades. There have been incidents involving radioactive material shipments but you can see - I can tell you first-hand that 20 these packages are extremely robust when we're talking about Type B packages, which is why they cost so much. Dr Sarkar will get into some of the testing requirements; they're also extremely expensive and in-depth.

MR JACOBI: You referred to incidents. Are they incidents were there's been 25 a breach or a failure of the containment and the cask?

MR DILLICH: No.

COMMISSIONER: So they've been transport incidents. 30 MR DILLICH: Right. The nuclear industry is fairly transparent and the safety culture is such that incidents, no matter how small, are looked into quite extensively and you try to extract lessons learnt from them and it's shared among the industry. Because what we've found out world-wide over the past 35 decades is, when there is something that happens in one country it's the fallout from that - and the fallout is a bad pun. But there are ramifications to the industry world-wide. It's a community that shares its lessons learned and it's very transparent. So you can go online and find out a lot about these incidents. You can read in-depth about what happened at them. The idea is it will prevent 40 possibly something similar happening elsewhere.

MR JACOBI: Can I just pick up the issue of - we've dealt with spent fuel and the commission is also concerned because of its terms of reference in considering issues of waste. We're also interested in I guess the packages that 45 are typically associated with the movement of waste and waste products, given

.SA Nuclear 17.11.15 P-1286 Spark and Cannon the particular form that that waste takes. So if you could take us through that.

MR DILLICH: Low level and intermediate level waste - and as I mentioned before, those are terms that only mean something in terms of ultimate storage 5 or disposal, not transport. They're generated through the nuclear fuel cycle, and other places, but nuclear fuel cycle from the production of radioisotopes for industry and also for nuclear power. There's all kinds of things. Radioactive waste: when we're talking about low-level radioactive waste, typically what we're talking about are rags and gloves - trash - that's 10 contaminated; ordinary items that in the course of doing whatever you're doing with the radioactive material becomes contaminated. Low-level waste is typically low specific activity waste. So typically it can be shipped in something other than a Type A or a Type B or a Type C package. It can be shipped rather easily. It's typically shipped in drums like the picture below. 15 There's a lot of different materials and so all these materials would be emitting a certain amount of low-level radiation. The composition of intermediate-level waste is much broader but it requires some amount of shielding. So the experience that Dr Sarkar and I might be able to expand upon in a bit has to do 20 with intermediate-level waste from research reactor use in Australia. That is intermediate-level waste, not high-level waste.

MR JACOBI: Can I just come back to the low-level waste. In terms of what you've referred to as a broad medley of scrap and trash products, is there an 25 evaluation that's made of that, given that it doesn't have a homogeneous quality? Is there an evaluation of the nature of the waste before a decision is made about packaging? How is that decision made?

MR DILLICH: Typically what's required is that the custodian, if you will, of 30 this waste will characterise the waste. Now, what that means is it's a laborious pain-staking process. What the person has to do is go through that waste using the proper PPE and protection and whatever and measure what kind of radionuclides are involved and how strong they are. Now, that's important to know, because if you know the radionuclides involved you can project up to 20 35 years what's going to be left, if anything, if it's short-lived or is it long-life radioactive isotopes.

A good example, and if you have a representative from ANSTO here, I know that, for instance, at ANSTO, which is one of our licence holders, they have 40 characterised all of their low level waste and have it drummed up in one particular licensed facility. You may even have a picture in there, don't you? This is all the low level waste that's been generated for some 50 years at the Lucas Heights facility. It's not a large volume, but they've done all that painstaking work, so they know each one of those drums, what's in it, it's all in 45 a computer database and that's what that is.

.SA Nuclear 17.11.15 P-1287 Spark and Cannon

MR JACOBI: In terms of then making a decision with respect to the transportation of that sort of material, again, is there a characterisation that's conducted or is there an assessment made? 5 DR SAKAR: Yes, in that case, when you want to transport (indistinct) and in that case that would be waste acceptance criteria, if you have a facility, and then the operator will propose that criteria to the regulator and that will dictate the type of packaging, and, again, depending on the type of facility, so the 10 waste acceptance criteria would be the key factor there, and that will determine the (indistinct) you must not exceed that sort of level, and you must not use this kind of waste, the chemicals, something like this you must not use in this package, you must transport it separately, so that sort of condition will come later on. 15 MR JACOBI: Again, the choice of package would depend upon the limit that's fixed as at the service of the package itself?

MR DILLICH: No, we have no experience because ANSTO has no place to 20 send it, so it's not going anywhere and we have no application for anything. Then just closing up with transport, in the United States, for example, there have been about 9,000 road shipments of defence related transuranic waste for permanent disposal in a deep geological repository in New Mexico, and almost half of the shipments were from Idaho, some distance away, using public roads 25 and that sort of thing, or rails in some cases.

The experience of commercial nuclear fuel, as I said before, that fuel is being stored at a number of sites throughout the United States, and ultimately it will be transported safely somewhere, wherever that is. 30 MR JACOBI: I think we've dipped into the discussion at the level of the categories of packages. I would just like to take a step back, and I was hoping you might explain how those particular packages are essentially applied as legal requirements under law, and perhaps we can then move back from their 35 earlier source at the international level.

MR DILLICH: Sure.

MR JACOBI: A similar slide might pick up the international regulatory 40 aspect.

DR SAKAR: Okay, thank you. Considering that transport is an integral part of the nuclear industry, or nuclear fuel cycle, or radiation business, so in order to assure the community there is some safety requirements in terms of 45 transporting radioactive materials, in 1961 I came up with the requirements to

.SA Nuclear 17.11.15 P-1288 Spark and Cannon be followed for transport of class 7 material, and that's, you know, all the safety requirements. Then these safety requirements are, again, you know, moved to the next level like (indistinct) transport requirement. In the global requirement, for example, the (indistinct) model regulation, which you call it (indistinct) and 5 it deals with all classes of radioactive material.

In the next slide, I will explain that a little bit more. Then you come to the type of transport. Depending on the (indistinct) of the transport, whether it is road, rail or air or sea transport then you, you know, impose the requirement, and 10 then finally it comes to your national regulatory process there, what you want to do and how you are going to adopt all these international requirements. We have to also acknowledge that in order to maintain our harmonisation in the global regulatory process we all need to follow the almost identical requirements so that there is no disharmony in the requirements. 15 If you go to the next slide. As you can see, it starts from (indistinct) what you call the regulation for safe transport of radioactive material. Now, we call it a specific safety requirement. It goes to the UN orange book, which is for all classes of radioactive material (indistinct) dangerous goods, and then it has one 20 chapter which directly incorporates the requirement of (indistinct) then depending on the type of the mode then your model regulation comes into practice, like (indistinct) for air transport (indistinct) for sea transport.

In Australian cases, what we do is use the declared option of the (indistinct) in 25 the road, rail and (indistinct) again, in Europe they have ADR, AND, and all are based on (indistinct) and then if you go to the next test slide in - - -

MR JACOBI: Sorry, can I just pick up, because I notice that's the 2012 edition of the safety standards. To what extent is there a progressive review or 30 updating of those standards?

DR SAKAR: Usually, the United Nations has a review cycle of two years, i.e. it tries to catch up with that, but in practice it does not happen. For example, from the 2005 edition we have 2009, 2012, and now in the last meeting we've 35 decided that we'll have another revision, so we can expect maybe three years' time there may be another revision, but UN orange book they usually do the review every two years.

MR JACOBI: Am I right in understanding that the Australian Code will then 40 be rewritten in accordance with it?

DR SAKAR: To update it accordingly, yes.

MR JACOBI: Does that apply by force by the ARPANSA Act? Is that Code 45 enforceable?

.SA Nuclear 17.11.15 P-1289 Spark and Cannon

DR SAKAR: It is through ARPANSA Act, plus, you know, in the next slide I will explain over in Australia we want to maintain the national uniformity so that all the states and territories follow the same code. We call it the National 5 Radiation Protection (indistinct) so all the states and territories are signatories of that, so they gave a commitment that they will follow this.

MR DILLICH: So our Act requires us to consider international best practice.

10 DR SAKAR: As you can see, Australia's regulatory framework, because Commonwealth regulator, ARPANSA, mainly regulate road, rail and inland waterways for Commonwealth entities through this code, and civil aviation is for air transport (indistinct) is applied by AMSA, that is, the Australian Maritime Safety Authority, and six states and two territories they have 15 (indistinct) and on the top of that, as you can see at the corner we have a group we call the Transport Competent Authority Forum, which is a national working group.

Through this group, with the regulator, we exchange information and share 20 information. In Australia we maintain the national uniformity, and if there's any issue we try to resolve it through this working group.

MR JACOBI: I want to deal with the Australian regulatory arrangements as they govern transport. I want to separate out and deal with, first of all, the idea 25 of the movement of radioactive materials and the process of actually transporting and separate that out from the (indistinct) validation packages. Perhaps you could explain just in broad terms what the requirements are in terms of a particular transport route or a particular transport pathway being approved. 30 DR SAKAR: The requirement is accordance with the ARPANSA Code or (indistinct) for example, in most cases because they do not need to consider the amount of activity involved in the transport. They do not need any regulatory approval for transport as such, however, in some states like Victoria they have 35 a process like the licence, the carrier, the company that does it, to make sure that they are trained, they follow this and that, so every state has an additional requirement for the transport. As I said, as long as they comply the (indistinct) and even numbering, all these requirements and all the declarations, in most cases they're okay. 40 If there is anything that needs approval, for example, in some cases you will find that the (indistinct) hospitals, they're an out of state design. For example, they're designed in the 1970s, which are obsolete, so once they want to transport they have to go through the provision of the code, we call it the 45 special arrangement, and in that case they have to demonstrate the safety case

.SA Nuclear 17.11.15 P-1290 Spark and Cannon that the safety is at least equivalent to the current standard. So in that case it needs to go through the regulatory approval process and in that case ARPANSA maintains that central database for approving some particular type of (indistinct) and they issue that, "Look, you use this number but let us now 5 make that nationally we know what is happening."

MR JACOBI: If I can come to fuel cycle activities. We've heard this morning about the transportation of uranium concentrate. I'd be interested in the extent to which that requires approval from a regulator and then what's examined 10 from the regulator's point of view with respect to such an activity.

DR SARKAR: Because these are done with a private industry it is mainly regulated by the state authorities. So what they do is, the owners attempt to make sure that they are in compliance with the requirement of the transport 15 code. It's the standard practice for a regulator time to time go and check the complaints monitoring, checking, "What did you do? Did you follow this and this?" and check the records, and sometimes they can do some reactor inspection also - unannounced inspection - as a part of the regulatory process.

20 MR JACOBI: But shifting to the sort of activities that ARPANSA regulates and thinking about a Commonwealth activity but if one was to theoretically talk about the movement of below-level waste, what would ARPANSA need to do in terms of examining an application to transport such waste?

25 DR SARKAR: Look, depending on, as I say, the size of the shipment, if the activity is low, in that case you do not need any regulatory approval for shipment. But if there is a case that there is a point B has a facility and you need to transport that low-level waste from point A to point B, in that case, looking at what will be the consignment, then ARPANSA may decide, "Okay, 30 look, you need approval because of this and this," then looking at all the safety aspect, "What is the transport plan, safety plan? What do you usually do for other - - -"

MR JACOBI: Does that require an examination of the - perhaps again to 35 come back to the potential for exposure to radiation from the public.

DR SARKAR: Exactly, and including, "All the accident conditions, what do you have? What do you have if there is like - what contingency do you have in place?" I mean again you have to again communicate in terms of the 40 emergency plan with emergency service and all this stuff needs to be there.

MR JACOBI: To what extent do you analyse the - I'm not suggesting you should go back and redo it - but examine the analysis of the characterisation of the way that you described before that a calculation was made of the 45 characteristics of the type of waste? Would you examine that sort of

.SA Nuclear 17.11.15 P-1291 Spark and Cannon information?

DR SARKAR: Yes. What happens through our inspection - for example, I will give you an example, they have a considerable amount of radioactive 5 low-level waste. How do they do the characterisation? Of course we need to look at the system itself there, the technical aspect also. Is the system calibrated? Do they have a quality management system in place? Like is it calibrated at a certain frequency to make sure it gives confidence in the measurement? What sort of standard deviation? Is it one standard deviation or 10 two standard deviations taken into account in the measurement - of course we do.

MR JACOBI: I think again picking up the need to transport spent fuel, as I understand Australian spent fuel is being sent overseas to be reprocessed, is 15 that an activity that you regulate?

DR SARKAR: Yes.

MR JACOBI: Can you just walk us through in broad terms from the regulator, 20 your perspective, what the analysis is that you make of such transportation and - - -

DR SARKAR: I will do it in the following way: for example, this is the flow chart and as you can see the orange box there is for ARPANSA. Once we 25 receive the transportation application for approval - and before approval we have to make sure the package that will be used - usually this is a licensed package because it's very expensive, so is it certified, properly certified. Then we do another assessment based on the original assessment. We use the safety case and we look at all the critical factors like if there's an accident, will it 30 withstand? Did the previous level take into account all of these factors? Then we validate the package; that is this package is authorised to use in Australia to undertake particular activity.

Then they submit the safety plan. That is how the shipment will be undertaken 35 safely and then we look at what are the operational controls in place: the back-up vehicle, communication system, exposure control, and the convoy will be supervised by health (indistinct) are the drivers trained. All these factors are taken into account and then we have another control in place to assure the public that it is done safely. We do the pre and post monitoring of the route. 40 Once we know the route, we do the pre-shipment monitoring, as you can see, and then we keep the record and then we do the post-monitoring to make sure that there is no contamination; it is identical what we did pre-shipment monitoring. Also, after this - - -

45 MR DILLICH: So that's actual radiological assessment, sir.

.SA Nuclear 17.11.15 P-1292 Spark and Cannon

DR SARKAR: Actual physical measurement of entire route. We have a vehicle monitor in system so we monitor the entire route. Then we look at that loading operation. We physically go there. We make sure they follow all the 5 right procedure. We look at the exposure to the operator during the operation, plus we also - so before that we have an all emergency meeting. All emergency meeting means you know that the regular, police, emergency - how it will be done and how it will be done if there is an emergency. Then we also did the debriefing also, and also we get the records from the licence holder that 10 what is the exposure record.

So far as I will explain it in the next slide if we turn - this is the thing that we consider in that - these are from the research reactor fuel. Please go to the next one. As you can see, in that case we have a coordination with MSA because 15 Maritime Safety is the authority for sea transport. So once we approve the safety plan, it also needs to be approved by the Maritime Safety Authority. They physically inspect the vessel because this is their area of expertise. Then we did so far all the HIFAR as well as the MOATA reactor fuel in nine shipment without any incident. We did not have any incident and all were 20 transported safely.

COMMISSIONER: It goes to France, does it?

DR SARKAR: France and some of them were sent to USA because US origin 25 fuel, under the bilateral agreement, they take back and they will take care of the - - -

MR DILLICH: So MOATA was a small reactor at the Lucas Heights site. It's not in use any more. HIFAR was a reactor that operated about 50 years and 30 it's no longer in use any more. Some of the fuel was shipped overseas to the UK, most of it to France, much to the US, but the US, with an agreement, takes it back, never to come back to Australia again. That's a one-way shipment.

MR JACOBI: I will try to come to the question of package design. I think 35 we've already picked it up in terms of - and perhaps you can explain in terms of an answer you gave before. Is most of the package analysis that you do in Australia validation of casks and designs that have already been done overseas?

40 MR DILLICH: Exactly. There aren't that many vendors who make Type B packages. In the United States there's three big companies that do that. The Europeans have a couple. So what we would do here in Australia is we verify the certification that's already been done.

45 DR SARKAR: We do one package, the new package. There is an Australian

.SA Nuclear 17.11.15 P-1293 Spark and Cannon package by a private company. We did it because that package will be used in overseas and I think that package was validated in Russia, in China and some other countries and it will also be used in the States. So we did one package a Type BU, a BU package, which will be used mainly for (indistinct) sources or 5 transporting caesium and cobalt sources.

MR DILLICH: So you can see why it's important for all member states to adopt the same standards from the IAEA.

10 MR JACOBI: Can I just pick up in terms of the regulatory oversight and perhaps a new package design because I suspect that's going to pick up much of what you might do in a recertification or a validation about what the regulatory process is that's associated with - - -

15 DR SARKAR: When we did the Type BU, just before that we are using what Mr Dillich has already mentioned, the Type B package, and this is the TN81 what we are going to use for (indistinct) return and if this can be used for spent fuel, the same package, and it's - - -

20 MR JACOBI: Sorry, just to take a step back, a TN81 is just a particular model of cask.

DR SARKAR: It's a model, yes.

.SA Nuclear 17.11.15 P-1294 Spark and Cannon