IAEA mission makes 11 recommendations
Main findings
The review team provides the following independent expert opinion, recommendations and suggestions for good practice:
Compliance with international radiation standards
The review team was not able to identify any non-compliance with international radiation safety standards.
However, the review team identified 10 issues for which it considered that improvements were necessary before the next licensing phases of the Lynas project. Those recommendations are listed below and discussed in more detail in the report.
The review team also added an 11th recommendation dealing with the manner in which recommendations 1–10 should be acted upon.
Recommendations
Where the review team considered that improvements were necessary, it made recommendations. The report presents and discusses the situations and bases for each of those recommendations separately. The following 11 important recommendations are made:
Technical recommendations
1. The AELB should require Lynas to submit, before the start of operations, a plan setting out its intended approach to the long term waste management, in particular management of the water leach purification (WLP) solids after closure of the plant, together with a safety case in support of such a plan. The safety case should address issues such as:
(a) Future land use (determined in consultation with stakeholders);
The review team provides the following independent expert opinion, recommendations and suggestions for good practice:
Compliance with international radiation standards
The review team was not able to identify any non-compliance with international radiation safety standards.
However, the review team identified 10 issues for which it considered that improvements were necessary before the next licensing phases of the Lynas project. Those recommendations are listed below and discussed in more detail in the report.
The review team also added an 11th recommendation dealing with the manner in which recommendations 1–10 should be acted upon.
Recommendations
Where the review team considered that improvements were necessary, it made recommendations. The report presents and discusses the situations and bases for each of those recommendations separately. The following 11 important recommendations are made:
Technical recommendations
1. The AELB should require Lynas to submit, before the start of operations, a plan setting out its intended approach to the long term waste management, in particular management of the water leach purification (WLP) solids after closure of the plant, together with a safety case in support of such a plan. The safety case should address issues such as:
(a) Future land use (determined in consultation with stakeholders);
(b) The dose criterion for protection of the public;
(c) The time frame for the assessment;
(d) Safety functions (e.g. containment, isolation, retardation);
(e) The methodology for identification and selection of scenarios – this must include the scenario in which the residue storage facility at the Lynas site becomes the disposal facility for the WLP solids;
(f) Any necessary measures for active and/or passive institutional control.
As the safety case is developed, the radiological impact assessment (RIA) for the facility as a whole should be updated accordingly.
2. The AELB should require Lynas to submit, before the start of operations, a plan for managing the waste from the decommissioning and dismantling of the plant at the end of its life. The RIA and decommissioning plan should be updated accordingly.
3. The AELB should require that the results of exposure monitoring and environmental monitoring once the plant is in operation be used to obtain more reliable assessments of doses to workers and members of the public, and the RIA updated accordingly. The AELB should also require that dose reduction measures be implemented where appropriate in accordance with the international principle of optimization of radiation protection.
4. The AELB should develop criteria that will allow the flue gas desulphurization (FGD) and neutralization underflow (NUF) residues to be declared non-radioactive for the purposes of regulation, so that they can be removed from the site and, if necessary in terms of environmental regulation, controlled as scheduled waste.
5. The AELB should implement a mechanism for establishing a fund for covering the cost of the long term management of waste including decommissioning and remediation. The AELB should require Lynas to make the necessary financial provision. The financial provision should be regularly monitored and managed in a transparent manner.
6. For regulating the Lynas project, the Malaysian Government should ensure that the AELB has sufficient human, financial and technical resources, competence and independence.
7. The AELB and the relevant Ministries should establish a programme for regularly and timely updating the Regulations in accordance with the most recent international standards. In particular, regulations pertinent to NORM activities relevant to the proposed rare earths processing facility should be considered to be updated.
Public communications recommendations
8. The AELB should enhance the understanding, transparency and visibility of its regulatory actions in the eyes of the public, particularly those actions related to inspection and enforcement of the proposed rare earths processing facility.
9. The AELB should intensify its activities regarding public information and public involvement. In particular, it should:
(a) Develop and make available easily understandable information on radiation safety and on the various steps in the licensing and decision making processes;
2. The AELB should require Lynas to submit, before the start of operations, a plan for managing the waste from the decommissioning and dismantling of the plant at the end of its life. The RIA and decommissioning plan should be updated accordingly.
3. The AELB should require that the results of exposure monitoring and environmental monitoring once the plant is in operation be used to obtain more reliable assessments of doses to workers and members of the public, and the RIA updated accordingly. The AELB should also require that dose reduction measures be implemented where appropriate in accordance with the international principle of optimization of radiation protection.
4. The AELB should develop criteria that will allow the flue gas desulphurization (FGD) and neutralization underflow (NUF) residues to be declared non-radioactive for the purposes of regulation, so that they can be removed from the site and, if necessary in terms of environmental regulation, controlled as scheduled waste.
5. The AELB should implement a mechanism for establishing a fund for covering the cost of the long term management of waste including decommissioning and remediation. The AELB should require Lynas to make the necessary financial provision. The financial provision should be regularly monitored and managed in a transparent manner.
6. For regulating the Lynas project, the Malaysian Government should ensure that the AELB has sufficient human, financial and technical resources, competence and independence.
7. The AELB and the relevant Ministries should establish a programme for regularly and timely updating the Regulations in accordance with the most recent international standards. In particular, regulations pertinent to NORM activities relevant to the proposed rare earths processing facility should be considered to be updated.
Public communications recommendations
8. The AELB should enhance the understanding, transparency and visibility of its regulatory actions in the eyes of the public, particularly those actions related to inspection and enforcement of the proposed rare earths processing facility.
9. The AELB should intensify its activities regarding public information and public involvement. In particular, it should:
(a) Develop and make available easily understandable information on radiation safety and on the various steps in the licensing and decision making processes;
(b) Inform and involve interested and affected parties of the regulatory requirements for the proposed rare earths processing facility and the programme for review, inspection and enforcement;
(c) Make available, on a routine basis, all information related to the radiation safety of the proposed rare earths processing facility (except for security, safeguards and commercially sensitive information) and ensure that the public knows how to gain access to this information.
10. Lynas, as the party responsible for the safety of the proposed rare earths processing facility, should be urged to intensify its communication with interested and affected parties in order to demonstrate how it will ensure the radiological safety of the public and the environment.
Follow-up recommendation
11. Based on recommendations 1–10 above, the Government of Malaysia should prepare an action plan that:
(a) Indicates how the above-mentioned recommendations are to be addressed;
10. Lynas, as the party responsible for the safety of the proposed rare earths processing facility, should be urged to intensify its communication with interested and affected parties in order to demonstrate how it will ensure the radiological safety of the public and the environment.
Follow-up recommendation
11. Based on recommendations 1–10 above, the Government of Malaysia should prepare an action plan that:
(a) Indicates how the above-mentioned recommendations are to be addressed;
(b) Sets out the corresponding time schedule for the actions;
(c) Is geared to the possibility of an IAEA-organized follow-up mission, which will review the fulfilment of recommendations 1–10 above in, say, one to two years' time, in line with other IAEA review missions.
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