Permission for Lynas to operate in Australia... not!

Lynas' executive chairman Nick Curtis claims that they have permission from the Australian government to set up the entire rare earth processing and waste disposal facilities in Australia. This license was actually granted to Ashton Rare Earth Limited in 1992, but was fully transferred to Lynas through a series of corporate exercise. Lynas has often used this license as a means to discredit the rationale of those who oppose the Lynas Advanced Materials Plant (LAMP) in Gebeng. After all, given Australia's tough environmental laws, if it is approved in Australia, why kick up a fuss in Malaysia?

An examination of Ashton's proposal and the 41 commitments tied to the approval shows that very strict environmental control measures have been imposed in Australia. As a matter of fact, looking at the way they are allowed to carry out their operations here in Gebeng, it is inconceivable that Australia will allow the LAMP to be built in such a state. Of the many aspects of operation that can be, and should be juxtaposed, I shall only address the waste management of the radioactive residue in this report.

Ashton originally proposed that the rare earth ore mined from Mt Welt be first semi-refined at the mining site. After that, the concentrate is to be transported by road to a secondary processing plant 880km away in Meenaar Industrial Park for final processing. Finally, the mildly radioactive waste was to be transported back to Mt Welt for burial.

Ashton had considered 4 disposal options, namely "burial at Mr Weld, on-site disposal at Meenaar, disposal in existing residues storage areas of disused mines, and disposal at the integrated waste disposal facility at Mt Walton". Out of the 4 options, the first was considered "to be the most environmentally responsible". [1;pg iii]

The residue was to be deposited in a series of impermeable, underground ponds, located off the carbonatite pipe to prevent contamination to the groundwater [1;pg ii & 36]. Ashton was required to monitor the movement of radionuclides and to submit the results annually to the Water Authority and the EPA [1;pg 61 & 62]. Remarkably, Ashton had agreed to ensure that the residues returning to Mt Weld would have less radioactivity than the original deposit [1;pg ix]. Finally, upon decommissioning the storage ponds, the residue "would be covered with a 2.5 m layer of soil, rock and topsoil, and rehabilitated" [1;pg 6].

The nearest population centre to Mt Weld is Laverton, located 35 km away [1;pg i], which had a population of 1,500 at the time of the proposal [1;pg 8], but has only 316 at present [2]. Although the sparse population density of Mt Weld was not specifically mentioned as a factor in the selection of the disposal site, the selection of the secondary processing site at Meenaar was [1;pg 23]. Therefore, it was likely that the disposal method was so thorough and the affected population so small, that the safety risk was considered too insignificant compared to the secondary processing plant to warrant the setting up of a buffer zone.

 It is truly admirable that the Australian government has gone to such great lengths to ensure that the radioactive waste poses minimal harm to her citizens. Yet, the specific activity of the residue for Ashton's proposal is only 2.3 Bq/g (converted to "parent" radioisotope method) [1;pg 36]. In contrast, it is almost 3 times of that for the waste in Gebeng which is 6.1 Bq/g [3;pg 38].

Using the same classification as Dr Lee Chee Hong's comments on the IAEA report, this level corresponds to the Very Low Level Waste (VLLW), as opposed to the Low Level Waste (LLW) for the waste in Gebeng [4;pg 16]. Dr Lee has used the radioactive waste classification system in the UK and it is illustrated in Figure 1.

Figure 1: Radioactive waste classification system used in the UK.

Dr Lee has correctly pointed out that the IAEA review of Lynas' operation ignored one of the critical general safety guides in the Radioactive Waste Classification. IAEA No. GSG-1 [5]. "It is recommended by the IAEA GSG, this waste requires robust isolation and containment for periods of up to a few hundred years and is suitable for disposal in engineered near surface facilities" [4;pg 16].

Not only has Lynas not disclosed their permanent disposal and decommissioning plans, they have originally intended for the site in Gebeng to be the final resting place for the radioactive waste [6]. In contrast with the 1,500 affected by Ashton's proposal, 700,000 people in the Greater Kuantan-Kemaman area falls within the 35 km radius from the Gebeng plant.

In addition, unlike the robust environment of Mt Weld, the LAMP is situated on a reclaimed swamp land. According to the Preliminary Environmental Impact Assessment, the ground water is only 0.95 – 3.5 m below ground surface [7;pg vii]. The high moisture level at the site is a cause of concern as it may affect the permeability of the containment tanks [8]. Not only has Ashton chosen to site the waste disposal facility away from the aquifer, the aquifer itself is deeper, located at 7 - 17 m below ground surface [1;pg 8].

If such meticulous waste disposal method is deemed necessary for VLLW in Australia, greater care should be undertaken for the more hazardous LLW. Instead, scant regard is given. As Lynas presses on with firing up the LAMP to take advantage of the astronomical rare earth price, no public disclosure whatsoever has been made regarding the permanent waste disposal and decommissioning plans. The only logical reason for Lynas to choose Malaysia as the final processing site is to circumvent Australian tight environmental regulations by exporting rare earth pollution here.

This is only the tip of the iceberg on the huge discrepancies between the Ashton proposal and the operation in Gebeng. Regulatory requirements on other areas of operation, such as transportation, water management, and pollution monitoring are equally stringent. Therefore, one can surmise that Lynas' flaunting its Australian license is merely a stunt in public relations.

If the Ashton's proposal is a testament on how rare earth processing should have been done, the LAMP is a disaster waiting to happen if it is allowed to proceed.



Soo Jin Hou
Kuantan Environmental Watch Group



References:
1. Proposed rare earths mining and beneficiation at Mt Welt, Laverton and secondary processing at Meenaar, near Northam - Ashton Rare Earths Ltd. Report and recommendations of the Environmental Protection Authority. Bulletin 646, August 1992.

2. Australian Bureau of Statistics, 2006 Census Quickstats. http://j.mp/qAeYvG

3. Radiological Impact Assessment of Advanced Materials Plant, Gebeng Industrial Estate, Kuantan, Pahang. Nuklear Malaysia. June 2010.

4. Comments on the IAEA Peer Review Report on radiation Safety Aspects of a Proposed Rare Earths Processing Facility (The Lynas Project), REF; NE/NEFW/2011[1]. Rev 0. Lee Chee Hong. 5th Aug 2011.

5. IAEA Safety Standard for Protecting People and the Environment, Classification of Radioactive Waste, General Safety Guide, No. GSG-1. Vienna, 2009.

6. Malaysian Insider "Lynas will start Kuantan plant, radioactive waste onsite". Shannon Teoh, Apr 12 2011.

7. Preliminary Environmental Impact Assessment and Quantitative Risk Assessment, Proposed Advanced Materials Plant, Gebeng Industrial Estate, Kuantan, Pahang Malaysia. Volume 1: Main Report. Environ Consulting Services (M) Sdn. Bhd. January 2008.

8. New York Times, The Fear of Toxic Rerun. Keith Bradsher, June 29 2011. http://www.nytimes.com/2011/06/30/business/global/30rare.html?pagewanted=all