LAUNCH OF REPORT ON THE DESCRIPTION AND CRITICAL ENVIRONMENTAL EVALUATION OF THE LYNAS ADVANCED MATERIALS PLANT IN GEBENG, PAHANG
The Lynas Advanced Materials Plant (LAMP) in Gebeng, Pahang, claims to be the world’s largest rare earth refinery project. Such industrial projects generate enormous volumes of toxic and radioactive waste and are linked with serious environmental pollution and health risks. LAMP is located in a densely populated area, with the nearest housing estate a mere 2 kilometres away and 700,000 people living within a 30 kilometre radius. It is the Malaysian subsidiary of an Australian company, Lynas Corporation, which mines rare earths in Mount Weld, Western Australia.
There has been widespread public opposition to the Lynas plant as Malaysians are painfully aware of the serious health and environmental hazards of processing rare earth elements, when there is no stringent regulation and control, reinforced by Malaysia’s unreliable maintenance and safety culture, as a result of irregular enforcement of the law, lax attitudes to safety regulations and procedures in occupational health, and inadequately trained and motivated personnel.
In the 1980s, the Asian Rare Earth (ARE) refinery company, owned by the Mitsubishi Chemical company, failed to safely dispose of its industrial waste, containing radioactive thorium hydroxide. Workers and the neighbouring community were exposed to ionising radiation, resulting in several birth defects and leukaemia cases among the 11,000 people living in Bukit Merah and Papan, Perak. Seven of the eight cases of leukaemia were fatal. Public protests and legal action eventually forced Mitsubishi Chemical to close its operations in 1992 and agree to an out-of-court settlement with the residents of Bukit Merah. The clean-up has cost the company an estimated US$100 million.
A similar scenario of health and environmental problems is unfolding among rare earth refineries in China, which possesses 57% of the world’s reserves of rare earth elements and controls 95% of the world’s markets.
It is important to understand the health effects of ionising radiation, which can be defined as radiation that has sufficient energy to displace
electrons from molecules. Human beings are exposed to radiation from both natural and man-made sources. Very high doses of radiation will damage tissues which can be evident within days after exposure, whereas low levels of radiation are insidious and may take years to show up late effects, such as cancer.
The report of the Biological Exposure to Ionising Radiation VII (BEIR VII) committee of the US National Academy of Sciences concludes that current scientific evidence is consistent with the hypothesis that there is a linear dose-response relationship between exposure to ionising radiation and the development of radiation-induced solid cancers in humans. In other words, there is no safe threshold of exposure to ionising radiation and, therefore, exposure to even the smallest dose has the potential to increase the risk to humans.1
Thousands of Malaysians have joined two non-governmental organisations, which have organised public protests, taken legal action, and demanded closure of the Lynas plant. But the Pahang state government and the federal government continue to dismiss public sentiment and openly support the project, which will inevitably contaminate the environment and cause health problems for the 700,000 people who live within a radius of 30 kilometres.
The plant in Gebeng will make a lot of money for Lynas Corporation, which has received a 12-year tax exemption, and for those Malaysians with vested interests in the project. Undoubtedly, it is the profit motive that is driving the project and suppressing genuine community concerns about public health and environmental dangers.
The Malaysian government and its business cronies have garnered the support of several groups who favour government policy and the Lynas project, including the Academy of Sciences Malaysia and the National Professors Council, who claim to have conducted ‘comprehensive’ studies and made an ‘independent’ joint report, Rare Earth Industries: Moving Malaysia’s Green Economy Forward.
While the report concedes that radioactive and chemical waste, generated by rare earth industrial plants, poses risks to health and the environment, it also incredibly claims that it is possible to manage and mitigate such risks safely, that “Malaysia’s regulatory standards on rare earths follow
international standards” and that “Malaysia’s regulatory regime is even more stringent than international guidelines.” 2
The two academic groups need to be reminded of the country’s litany of serious industrial accidents and the government’s breathtaking abandonment of fundamental principles and mandatory procedures, when it issued a construction licence for the massive, polluting Lynas plant in 2008 before the completion of a detailed Environmental Impact Assessment. In addition, the Atomic Energy Licencing Board (AELB) also jumped the gun when it issued Lynas a Temporary Operating Licence on 30th January 2012, not having made an unbiased, independent assessment and evaluation of the risks posed by the plant. This reflects some of the cavalier attitudes of some government ministries and their regulating bodies.
Having grave doubts that Lynas is in a position to genuinely guarantee the safety of its temporary and permanent disposal of its toxic and radioactive waste, two non-governmental organisations have organised public protests and submitted appeals and affidavits by technical experts.
Realising the importance of independent environmental assessment and evaluation, one of the NGOs, Save Malaysia Stop Lynas, commissioned Oeko-Institut e.V. to assess and evaluate the risks. Oeko-Institut is a leading European research and consultancy group, based in Darmstadt, Germany, with a reputation for sound engineering practices and a commitment to ecology and human welfare.
Summary of Oeko-Institut report
Oeko-Institut was tasked with:
- independently checking whether the technical standards applied by Lynas meet “best available technology” and sustainability criteria
- clarifying the risks and consequences of any failure of control and lack of adequate oversight
- recommending necessary controls and oversight to limit risks and consequences, if any.
Lynas’ production process
The production process consists of four stages:
- Cracking stage: In this first stage, the ore concentrate (which contains the radioactive elements of thorium and uranium) is dissolved by mixing it with concentrated sulphuric acid and heating it to 350 – 450oC. Sulphuric acid vapour and sulphur dioxide in the gas stream are treated in the flue gas desulphurization (FGD) facility, and neutralised with lime (CaCO3) to form a mixture of gypsum (calcium sulphate) and calcium sulphite.
- Water leach and purification process: The concentrated sulphuric acid solution with the dissolved materials is diluted with water and treated with magnesium oxide to reduce the pH of the solution, thereby precipitating several by-products. Insoluble ore concentrate components and precipitated by-products are filtered, washed and finally transported as a paste to a storage facility (water leach purification residue storage facility, WLP-RSF).
- Separation stage: The solution is then mixed with hydrochloric acid (HCl) and the different rare element chlorides are extracted in seven single extraction stages, after removing impurities.
- Product-finishing stage: The different extraction liquids are treated with sodium carbonate, neutralised with magnesium oxide and precipitated with sodium carbonate solution or with oxalic acid, filtered, and either marketed as such or followed by additional stages to yield marketable products.
Input materials of the refining process
The input materials of the refining process consist of the following:
- Ore concentrate
- Water, either as raw water or as supernatant solution, as well as precipitation collected from the water leach purification (WLP) storage pond.
- Natural gas for heating the kilns.
- Concentrated sulphuric acid for digesting the ore.
- Concentrated hydrochloric acid for the separation stage.
- Magnesium oxide for neutralising the hydrochloric acid.
- Soda ash and lime for neutralising the hydrochloric acid.
- Oxalic acid for purification of products.
- Solvent and kerosene for separation and extraction.
Output materials of the refining process
The output materials of the refining process consist of the following:
- Diverse rare earth elements (lanthanum, cerium, praseodymium, etc) which are marketable products.
- Discharged waste water.
- Discharged offgas.
- Several waste streams to be stored, re-used or disposed.
- Used chemicals, especially solvents and kerosene, to be treated, cleaned and recycled externally.
The environmental impact of the Lynas plant will largely be determined by the manner in which the plant’s input materials are transported and stored and its toxic and radioactive waste managed.
The Oeko-Institut report has expressed grave concerns about the inevitable consequences of Lynas’ incoherent waste management concept. The absence of relevant data in documents prevents any reliable accounting for all toxic materials introduced into the process, such as the amounts of toxic by-products present in the ore concentrate, including thorium.
The Lynas toxic and radioactive waste problem
The Lynas plant in Gebeng has a serious waste problem. It is estimated that it will import 66,000 tonnes of ore concentrate from Australia every year and process the ore to yield about 22,000 tonnes of high purity rare earth metals, which will then be exported to the United States, Europe and Japan where they will play a strategic role in high technology industries for manufacturing consumer goods, such as computers, mobile phones and hybrid cars.
In the process, the Lynas plant will also produce enormous amounts of toxic and radioactive waste. The production of every tonne of rare earth metals will generate 8.5 kilograms (18.7 lbs) of fluorine, 13 kilograms (28.7 lbs) of dust, 9,600 – 12,000 cubic metres of waste gas (containing dust concentrate, hydrofluoric acid, sulphur dioxide and sulphuric acid), 75 cubic metres of acidic waste-water, and about one ton of radioactive waste, including thorium and uranium. So, multiply these figures on
waste by a factor of 22,000 and it will give you a clear picture of the total volume of waste, amounting to about 220,000 tonnes (including 120 tonnes of radioactive thorium), to be disposed of every year.
In addition, the process will use up and pollute 500 tonnes of clean water every hour. This enormous volume of polluted water will then be discharged into the BalokRiver and will eventually contaminate the South China Sea.
Each of the three waste streams, which stem from the three different stages of the plant – Water Leach Purification (WLP), Neutralisation Underflow (WUF), and Flue Gas Desulphurization (FGD) – will have a very different composition.
It is unfortunate that the documents, made accessible to Oeko-Institut, did not provide complete or reliable information on the leaching characteristics of the wastes, which would determine subsequent storage and disposal of the wastes. However, it is likely that 99% of the radioactive thorium and radium constituents in the ore concentrate are present in the WLP waste stream.
As such characteristics of the three waste streams are not known, only a few “generic” assumptions could be made, including that the radio- toxic and chemo-toxic constituents of the waste would be fully soluble and geochemically mobile.
Waste storage on-site
The three waste streams containing wastes, which should be classified as “long-living low radioactive and hazardous wastes,” will be stored on-site in dedicated facilities, called “Residue Storage Facilities (RSF).
The poor design of the liner system of the RSF will include the use of a single barrier, instead of independent multiple barriers. This will not guarantee safe, leak-proof storage of radioactive and hazardous waste.
In fact, the preliminary Environmental Impact Assessment (EIA) has made an astounding finding and identified such a danger: “The potential leaching of trace metals, including radioactive lanthanide metals, from the residues may result in contamination of the underlying soil and groundwater resources.”
Incredibly, the preliminary EIA evaluates the technical measures to prevent leakage as adequate and recommends the “monitoring of groundwater in the vicinity of the RSF…on a regular basis.” But monitoring groundwater will not prevent leakages.
The design of the RSF facilities is therefore technically inappropriate because it does not prevent leakage. It will allow radioactive and toxic wastes to leak and enter the natural layers of earth under the Lynas facility and reach the groundwater table. It will therefore be impossible for the Lynas plant to contain such radioactive contamination of the environment.
Emissions of radon gas
Radiation risks from the emission of radon gas from the Lynas plant are small. But it is unscientific and misleading to dismiss them by equating them with natural background radiation levels, because the risk from background radiation is not zero. It should be emphasised that there is no safe threshold for radiation. All radiation is harmful to health.
Emissions of sulphuric acid and dust
Waste gas from the heating of the ore with concentrated sulphuric acid is treated to remove dust and other substances, but waste gas from the roasting of rare earth oxalate is not filtered for dust and is discharged directly into the atmosphere.
Analysing and comparing these emissions, the report concludes:
- that no reasons are given for not providing a comprehensive system to treat all waste gas and remove dust;
- that Malaysia’s environmental regulation of air quality is inappropriately lacking in current scientific knowledge and technical advances in the reduction of emissions;
- that Lynas’ treatment systems for abating acids, acidic gases and dust do not conform to the best technology available. As a result, sulphuric acid and dust emissions are too high by at least a factor of two.
In other words, Lynas is not keeping up with scientific advances in waste management.
Discharge of waste through water pathways
Lynas uses large volumes of clean water in the cracking stage of the process, at the end of which the polluted water is channelled through an earthen channel over three kilometres into the BalokRiver and eventually into the South China Sea.
The report concludes:
- that, as Lynas does not provide information on the by-product content of the ore concentrate in its Preliminary Environmental Impact Study, complete calculations cannot be made for other toxic constituents of the ore;
- that Lynas also does not provide full information or evaluations on the specific constituents of the waste-water, including their identities, concentrations and environmental impacts, as would be normally required in any Preliminary Environmental Impact Study.
- that it is unacceptable that the discharge of waste water containing toxic constituents in an open earth channel is accessible to humans and animals. Such toxic waste water should be discharged through a pipeline that will prevent seepage into groundwater and unintended use of the water.
The report therefore throws into doubt the validity of the Preliminary Environmental Impact Study.
The control of hazards in the production process
Any industrial facility, which makes use of and stores large amounts of concentrated acids, carries the potential risk that storage tanks will leak. Therefore, preventive measures, rapid detection of leaks, and ability to limit environmental damage should receive priority.
However, the report confirmed:
- that the assessment of specific environmental hazards to soil and groundwater, following tank leakages and sulphuric acid vapour release, was inadequate.
Wastes from the production process
From its detailed analysis of waste management by the Lynas plant, the report concluded:
- that the design of Residual Storage Facilities is defective, with regard to preventing leakage of radioactive and toxic constituents into the near groundwater, even under normal operating conditions. As the layers under the plant are not qualified as barriers and do not guarantee the enclosure of those constituents, seepage is not substantially reduced or delayed. It is an open question whether such an inappropriate design is compatible with the minimal requirements laid down in Malaysia for the control of radioactive waste and its storage.
- that the Residual Storage Facilities for waste from the Water Leach Purification process, containing the highest radionuclide content, has several defects, such as:
– a limited capacity for storage
– inadequate design for safeguarding against heavy rain and for protecting workers from exposure to radioactive waste
– the lack of a design to cope with enhanced enrichment of radium and the absence of any procedure for dealing with such wastes. Clearly, the increased risks to workers has not been recognised and planned for.
- that the Residual Storage Facilities should not be designated as a permanent disposal facility, because of significant deficiencies in the choice of a suitable site, the design of the facility, and the long term isolation of the facilities. Of particular importance is that the base layers of the facility are insufficient and cannot now be upgraded to meet the more stringent requirements of a permanent radioactive waste disposal site.
- that the option of releasing Water Leach Purification wastes to the public domain, either in their original form or in a mixture with other diluting substances, such as concrete or fixing agents, would expose workers and the public to excessive radiation from direct gamma rays. This option will pose an unacceptable risk to the general public and should be banned and ruled out completely.
- A safe and acceptable way to establish a permanent disposal facility for the waste must remain a prerequisite for the management of these wastes. This will include a comprehensive commitment to safety, a sound site selection, the broad consent of the affected public, and a carefully scrutinised licence for construction.
It is one year since the Atomic Energy Licensing Board issued a Temporary Operating Licence and yet a site for a permanent disposal facility has yet to be identified. It is beyond argument that no waste generation should be allowed, until all necessary measures have been undertaken to build such a facility, compatible with the required safety standards.
In addition, the Malaysian government’s approach and attitude towards ensuring adequate funds for decommissioning, clean-up and waste disposal leaves much to be desired. This is yet another good reason to oppose the Lynas plant and protect future generations from the hazards of toxic, radioactive industrial waste. It is also a good reason to replace the current pro-business government, which is deaf to the cries of the public and incapable of responding to public concerns about health and environmental safety.
It gives me great pleasure to launch the release of this important report.
- Biological Effects of Ionising Radiation VII report, The National Academy of Sciences. http://www.nap.edu
- The Academy of Sciences Malaysia and the National Professors’ Council report. Rare Earth Industries: Moving Malaysia’s Green Economy Forward, August 2011.