Z2 Nuclear-Lynas 1 (E)

Comments on Lynas Corporation’s Reports on its Proposed Rare Earth Extraction Plant Being Built in Gebeng (near Kuantan city in Malaysia)

 by Technical Consultant (June 24, 2011)

I have reviewed the report submitted by Lynas as well as the Lynas EIA (Environmental Impact Assessment) dated January 2008, together with other information available from the Lynas website. I submit the following comments. Admittedly, some of my comments are based on assumptions that may be incorrect or inappropriate due to inadequate information (mainly because Lynas’ report lacks full disclosure).

Lynas EIA (Environmental Impact Assessment) dated January 2008 is only a Preliminary Report. Unless the Malaysian government authorities have received subsequent reports, this is inadequate for the purpose of making a decision to grant Lynas an Environmental License. The reasons are as given below:

a.       It lacks details on the products, waste materials generated, Lynas’ intended treatment of wastes, and their impact on the environment. It cannot be envisaged how the Malaysian government authorities can evaluate the proposed project properly with such lack of details.

b.      The proposed Lynas plant to be built at Gebeng near Kuantan city is one which will treat Rare Earth Oxides (REO) using very strong acids to dissolve the minerals under high temperatures. This will result in emissions of acid fumes together with RE (rare earth) particles that are radioactive. It is the total amounts of such pollutants that will impact the environment. Because of the large amounts of materials to be processed (660,000 tonnes of enriched REO concentrates will be treated per year), the volume of toxic and radioactive wastes produced per year and accumulated over time is definitely huge.

c.       No chemical content of the liquid wastes produced during rare earth extraction was given. Lynas proposes to put the liquid wastes in decanting ponds to remove suspended solids, after which the liquids will be discharged into Balok River and ultimately into the South China Sea.

Lynas makes no mention of pollution from the phosphate minerals and phosphoric acid used at the plant. Phosphorous will cause algae bloom (especially red algae) that can destroy the fishing industry along the East Coast of Peninsular Malaysia; 

d.      My biggest objection to this report is it fails to deal with the uranium content, with Lynas claiming that the uranium content is of acceptable low levels.

e.       All the above give alarming results. It infers that Lynas is planning to discharge into the South China Sea, via Balok River, 303.28 tonnes of Thorium Oxide (it is possible Lynas does produce Thorium Oxide despite its denial) and 19.16 tonnes of Uranium Oxide. It is criminal negligence for anyone to discharge 19.16 tonnes of uranium oxide (yellow cake) into the South China Sea each year.

f.        To put the above into proper context, the recent disaster at the Fukushima nuclear plant involved only 9,000 tonnes of slighted contaminated cooling water which was discharged into the ocean. This water contained radioactive Iodine (with a half life of 30 days). Fish with detectable radioactive iodine was found off California within a week. Imagine the disaster if 19.16 tonnes of Uranium Oxide together with 303.28 tonnes of Thorium Oxide is discharged into the South China Sea each year. It would render all seafood in the region unfit for human consumption. It will destroy the lucrative fishing industry not only of Malaysia but also that of Thailand, Cambodia, Vietnam, Philippines, China and Indonesia.

 

1.      Radiation Hazards from solid wastes Lynas has always countered any expression of fear about the radiation effects associated with this project by claiming that this thorium content is low at 1.6% ThO_2.  Note, however, that the total Radiation Effect (hazard) is as calculated below:

Radiation Effect is proportional to:

(Mass of Radioactive Material) X (Radiation Rate) X (Time Exposed to Radiation) X (Distance from Radiation Source)

Lynas is proposing, according to its EIA Report (Section 5-55), to store radioactive waste in a PVC-lined (polyvinyl chloride) pond on a temporary basis!

Lynas is also proposing to produce 145,200 tonnes of radioactive waste per annum. These will continue producing harmful radiation almost perpetually (bearing in mind the half-life of thorium is 14.5 million years!).

According to Lynas’ own admission, the radiation rate (145,200 tonnes averaging 13.90 Bq/gm radiation value) exceeds many fold that of the Japanese Standard of 0.3 Bq/gm. And Lynas is planning to remain in operation for 10 to 20 years. This will give rise to a huge radioactive dump in a densely populated area. The whole Kuantan area together with thousands of hectares of surrounding land potentially can become a disaster area. 

The storage method for radioactive waste as proposed by Lynas is totally inadequate and does not meet international standards. Such wastes must first be dried and then stored in radiation-proof bunkers, i.e. in lead-lined steel containers and in triple-walled thick waterproofed concrete outer and inner walls with a lead middle wall. The wastes should not be stored at the plant site or near any populated area or in areas where seepage can contaminate ground water (especially water supply). We must be conscious that the half life of thorium is 14.5 million years. Thus, the thorium will take a minimum of about 50 million years to become non-radioactive. In many countries, such storage dumps for radioactive material are located underground in deep caves in geologically stable areas.

2.      Gaseous Emissions Lynas has not addressed the issue of gaseous emissions from the desulphurisation plant. Such contaminations would pose a much greater health hazard as these would be inhaled.

3.      It is likely it has a scrubbing circuit to produce solid wastes from this plant. Due to the high acid environment the process operates under, it will not be surprising there is a potential problem of acid rains from its gaseous emissions. The harm from any radioactive substances from the gaseous emission is many folds more dangerous as these could be inhaled. Any radioactive material and acid fumes would be spread over a huge area.

4.      Gypsum and Chemical Calcium Carbonate Lynas has announced that these are saleable products and there is a ready market in Malaysia. It is important that these must contain absolutely zero radioactive material.  If radioactive gypsum is used by the building industry, it will cause worse health hazard than what asbestos did a few decades ago. Buildings using gypsum construction material (even with slight radioactivity) will be condemned and the gypsum will have to be removed at great cost.

Chemical calcium carbonate is commonly used as a soil conditioner in fertilizers. If this is radioactive and used in the oil palm industry, it could render the palm oil not fit for human consumption. This could threaten the whole Malaysian palm oil industry.

5.      Waste Concrete Slabs Lynas has proposed to get rid of its toxic wastes as inert concrete slab. This method is banned in many countries and if these are radioactive as well, the hazard is increased many fold. Such slabs could be used as pavement and in parks.

6.      Economic Benefit  There is minimal financial benefit from this project for Malaysia since the government has given Lynas a 12 year tax holiday, with a planned project lifespan of 10 years and potentially extendable for a further 10 years. Essentially, the Lynas Gebeng Plant is a rare earth enrichment plant treating raw material from the Mt Weld Mine in Western Australia. All potential toxic and radioactive wastes will remain in Malaysia.

7.      The employment opportunities are minimal as this plant does not require many workers. Most of the Malaysians employed will be unskilled labour. It only requires a few technical and management staff and most of these would be expatriates.

Technology Expertise Outside China, there is no expertise for a REO enrichment plant on the scale that Lynas is proposing. China produces more than 85% of the world’s REO. The Chinese plants do have serious environmental problems and many are being shut down for this reason.

I hope my comments highlight some of the technical issues that Lynas must be made to address to the complete satisfaction of all. I admit that the calculations I have made in this are based on many assumptions due to the scanty information made available to me. I can only attempt to highlight issues that can form the basis for Lynas to answer. If these have already been adequately addressed, it would have allayed public concerns and misunderstandings. It is obviously in Lynas’ interests to do so anyway, as a good corporate citizen, to win public goodwill and support to protect its investment. Otherwise, Lynas can be accused of non-transparency by such non-disclosure or lack of full disclosure. The onus is on Lynas to address all the environmental risks associated with its project. It is also the responsibility of the Malaysian authorities to ensure that Lynas does so before any operating licenses can be issued to Lynas. The Malaysian authorities should be more focused on these as there is already a precedent set by the Asia Rare Earth disaster of Bukit Merah in Malaysia in the past. And that was only a 4,000 tonnes of REO per annum plant (the biggest plant at that time). Failure to do so on the part of the Malaysian authorities could have disastrous effects on the health and welfare of Malaysia. There could also be grave liabilities if the fishing industries in the South China Sea region are threatened or destroyed.

Malaysia should seek advice from China which has real experts with practical experience. It should be noted that the Chinese Government has been shutting down many such plants due to environmental issues. China has also announced that it is formulating new regulations to avoid any further disasters.

I cannot help but feel that the attitude of Lynas is one of arrogance due to its lack of openness and reluctance to have any serious public consultation. It should realise that to have a successful operation, it requires the full cooperation of the local population besides meeting all the environmental compliance standards set by the government. Lynas’ reluctance to engage in full disclosure or its tendency to make statements which are not fully backed-up with facts only makes one suspicious of its integrity.

..........

This message is sent by Dr. Kai-Lit Phua, API Fellow, Malaysia

6-28-11