Hi all just noticed this comment #77 from the AELB posted 2 hours.
DG AELB• 2 hours ago Thank you everyone for the constructive comments.
At the outset, let me introduce two minor editorial amendments in the article. First, insert a comma after "report" in the sentence "In a published report, on June 28, 2011, an International Atomic Energy Agency review team...." and second, delete "are" in another sentence for it to read "Bearers of these positions are......."; and I regret these errors.
Contrary to seditious rumours, let me assure you that AELB is in the process of carefully studying the pre-operating stage documents submitted by Lynas. These are very important documents as they are legal submissions made by Lynas as to what they claim to, shall and must do to be in full compliance. Until deemed satifactory by AELB, they will have to be amended, augmented and re-submitted by Lynas. Some had been re-submitted several times to date. Subsequently, an inter-agency panel of experts will then further scrutinise the accepted documents. The Panel includes experts from the Department of Environment (DOE), Ministry of Health (MOH) and several others. After careful review, including interviews with Lynas, this Panel and AELB will then submit recommendations to the 5-AELB Board for a decision. As practised in many other States, once approved the public will be shared the documents by the applicant for comments.
If and when a Pre-Operational License is issued, taking into account credible public comments, if any, AELB will use the conditional and controlled pre-operational stage to further collect and verify the plant's operational safety data that almost everyone has been asking for i.e. how much and what is the radioactive content of the residue, what is is heavy metal content in each residue component, what if mass input does not balance with the mass output, can the plant be safely operated, should the plant be corrected before further trial runs, etc.
Now turning to the issue of consistency, please note that AELB and I have have tried our utmost to be very consistent throughout this episode but have always been misreported. We have always stated that if national and international requirements are met at each and every stage of the multi- licensing process, Lynas will be allowed to operate. Failure or non-compliance would either mean non-issuance of license or suspension of operation and license. All regulatory decisions are based on legal technical considerations and provisions derived from best practises, international standards and national requirements or regulations.
On the issue of residues produced or processed, AELB and I have also constantly stated that if the specific radioactivity level is similar to background or is less than the internationally set level of 1 Becquerel per gramme, residues may be released from the regulatory control of AELB. This, however, does not mean out of DOE's control. Heavy metal content and other non-radioactve contaminants must be below the stipulated levels for it to be released from separate DOE legal requirements. Please note that any one time there can be at least 4 regularatory authorities monitoring and verifying the operations.
On IF's and MAYBE's, it is important to note that in any risk management, these type of assumptions are critical for planning state of preparedness. As examples, in nuclear power reactor safety design, what IF a tsunami ensues directly after a devastating earthquake. In car insurance, MAYBE the insured sum is inadequate. This useful and essential academic exercise on IF's and MAYBE's goes on until economic considerations requires a halt.
By the way, the 4 radiation workers that were previously contaminated in the medical cyclotron facility are now at work, continuing to provide radiopharmaceuticals for patients at more affordable prices in Malaysia, which otherwise would have costed the affected local population 6-7 times more per medical imaging procedure if imported. AELB will continue to monitor all radiation workers health while at the same time respecting their privacy. Act 304 requires that we monitor radiation workers and keep health records for 30-year periods to ensure safety, as well as, facilitate accountability, liability and compensation, if legally appropriate.
Lastly, everyone is welcome to come by AELB to check out if AELB and I are real, credible and doing our level best to serve you and to keep you and your family radiologically safe.
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