Today's chart & trading, page-418

From the IAEA 2011 review:
Recommendation 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.

From the IAEA 2015 review:
The fee adequacy for covering the cost of the long term management of waste including decommissioning and remediation is undetermined.

Given the limited understanding of the fund’s financial basis, the fee adequacy of the US $50M to cover worst-case disposal costs and decommissioning and environmental remediation measures costs could not be assessed by the team as appropriate or not. The review team suggests that the fund’s financial basis and adequacy be assessed against an appropriate estimate of the potential future liability e.g. an engineering estimate of projected WLP and decommissioning/environmental remediation waste volumes, PDF construction, etc. Further, documentation of the fund’s basis, and any changes to its receipt schedule should be made publicly available consistent with other key licensing documentation.

The 2015 IAEA also examined performance with respect to decommissioning-related Recommendations 1 & 2 (see below) of the 2011 IAEA review; performance was a mixed bag and certainly open to criticism.

I am convinced that Recommendation 5 will be a primary target for attack by Fuziah and Wong. They will demand that the underlying plans be "adequate" to determine appropriate decommissioning bond/fee/whatever, which for all intents and purposes means everything from design to capex/opex.

BOTTOM LINE: To believe F&W will conclude $50,000,000 is adequate, you'd have to be a walnut.
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Recommendation 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 case4 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.

Recommendation 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.