experts opinions on the lynas rare earth, page-5

Our taxes at work, email to ARPANSA:

"Dear Sir/Madame,

I am concerned that Dr Peter Karamoskos has been identified as your representative at a recent seminar in Malaysia regarding the Lynas rare earth refinery project.

Was Dr Peter Karamoskos officially representing ARPANSA at this seminar and did ARPANSA provide financing, either in part or whole, to facilitate his attendance?

At http://aliran.com/15658.html he is quoted: “Dr Peter Karamoskos, a nuclear medicine physician and radiologist and public representative on the Radiation Health Committee of the Australian Radiation Protection and Nuclear Safety Agency (Arpansa), explained to the audience how international radiation safety standards are set and promoted. He commented, “The International Atomic Energy Agency (IAEA) acknowledges that radioactive waste poses a threat to human health and therefore must be managed properly in a scientifically sound manner. We cannot determine if a project is safe until there is transparency both at the company and the governmental levels. In the case of Lynas, the lack of transparency is a major problem. Malaysia really has to make sure its regulation is implemented to prevent any runaway risk to the public for many generations to come.””

Given Dr Karamoskos is identified as an ARPANSA representative I would ask if he has read the IAEA report on the June 2011 review of the Lynas processing facility and accepts or rejects the conclusions? http://www.iaea.org/newscenter/news/pdf/lynas-report2011.pdf

Specifically the following 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 case1
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;
(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;
(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.

Before attending the 24th Nov 2013 seminar organised by two Malaysian protest groups, SMSL & Himpunan Hijau, and making the attributed comments did Dr Karamoskos consult with both the AELB & Lynascorp to gain a current understanding of the levels of compliance with the IAEA recommendations in order to present a balanced view?

As a Lynascorp shareholder I am particularly concerned at your representatives comment “We cannot determine if a project is safe until there is transparency both at the company and the governmental levels. In the case of Lynas, the lack of transparency is a major problem.” when there appears to be considerable information in the public domain suggesting Lynas has complied with all the relevant recommendations above.

In light of your representative’s comments I would ask you to review the current state of compliance and either qualify the “lack of transparency” or withdraw the comment.


PS: You may also note that the IAEA report appears greatly at odds with most of the findings of other panellists, particularly the radiation levels as determined by Gerhard Schmidt, Oeko Institute."