Re: Visit to Singapore High Commission over the Lynas Advanced Materials Plant (LAMP)
The committee members of Himpunan Hijau 2.0 handed letter to Singapore High Commission
With regards to above matter, we, a group of concerned residents from Kuantan, appreciate the opportunity given to us to bring to your attention the potential health and environmental risk of the Lynas Advanced Materials Plant (LAMP) in Gebeng, Kuantan to the surrounding areas including neighbouring ASEAN countries.
For the sake of brevity, we shall summarize the potential effects on Singapore in this text, and some of the justification of our assessment in the appendix.
The Lynas Advanced Materials Plant (known as “LAMP” herein) will commence its operation to process enriched rare earth ore (known as concentrates herein) and yield high purity rare earth oxides. The rare earth mineral will be mined at Mount Weld, Western Australia and subsequently enriched onsite prior to trucking to Port of Fremantle, 1000 km away. The concentrates will be loaded into the 20-feet containers and commenced a 4000 km sea voyage to Singapore, where c.a. 4000 containers/year will be unloaded to smaller vessels prior to heading to the Port of Kuantan. The intended load to LAMP is approximately 65,000 tonnes/year (dry base); 80,000 tonnes/year (wet base). The rare earth oxides are inherently harmless, however, two elements bound with the rare earth to form the ore, are radioactive, i.e. thorium and uranium.
The LAMP processes require substantial amount of chemicals and reagents, such as sulphuric acid, magnesium oxide, hydrochloric acid and utilities such as raw water and natural gas. These are required to extract the rare earth oxides and to generate copious amount of wastes including three types of gypsum, i.e. Flue Gas Desulphurisation (FGD), Water Leach Purification (WLP) and Neutralization Underflow (NUF) residues, flue gas and waste water. In other words, operations cannot start and continue without the creation of waste.
It is the intention of Lynas to “purge” almost all radioactive materials (thorium and uranium) and to channel them to a sole waste stream, known as WLP. The radioactivity concentration in the other 4 waste streams is regarded as either non-detectable or negligible. The table next page summarizes the characteristics of each waste stream:
Waste stream Amount Radioactivity Disposal method
Waste water 500 tonnes/hour Negligible Discharged into Balok River, which leads to the South China Sea
Flue gas 99,344 Nm3/hour Negligible Discharged through smoke stack into the atmosphere
NUF residue 177,820 tons/year Total activity 0.52 Bq/g Commercialized as fertilizers
FGD residue 58,920 tons/year Total activity 0.47 Bq/g Commercialized as gypsum board
WLP residue 64,000 tons/year Total activity 62.3 Bq/g Commercialized as road building material, failing which it will need to be permanently isolated
The commercialization of the wastes is still in the R&D stage. There is no indication that there are any interested buyers for these recycled products. Even if there is, there are serious implications of such disposal methods, as products containing trace amounts of radioactive elements will be sold throughout Malaysia, and possibly Singapore.
Lynas intends to commence operation while figuring out what to do with the waste. In the meantime, they will store the solid residues on-site in open storage ponds, as they have not yet identified the Permanent Disposal Facility (PDF) where the radioactive wastes are to be buried.
We are very concerned that LAMP poses real risk of contamination because:
1) the site of the plant is on a reclaimed swamp land, and the underground water table is merely 0.95 – 3.5 m below surface.
2) the low-lying area is prone to flooding due to the monsoon rain.
3) the New York Times reported serious construction and design flaws that “have the potential to cause the plants critical failure in operation” [1,2].
4) the half-life of the primary source of radioactivity, i.e. thorium-232 is 14 billion years. This may result in the accumulation of radioactivity over time from “negligible” sources
We feel, therefore, that the LAMP will bring serious repercussions to the people of Malaysia and Singapore. It may affect Singapore via these scenarios:
a) Food security
Kuantan is a major seafood producer with 390 registered deep sea trawlers. Significant seafood caught in Kuantan ends up in Singapore. Radiation risk may spread across border through radioactivity accumulated in the food chain.
b) Other sources of contamination
Other pathways may come from products that are made with contaminated materials, for example, palm oil, birds nest, fruits and vegetables, as well as Lynas’ proposed products that are made with their wastes. The US found out the consequences of using gypsum board made with FGD-type residue, and had in 1989 banned the use of this product. Also, the US EPA also noted that the use of fertilizers made with NUF-type residue can increase the radioactivity of the produce . Lynas must not be allowed to spread their pollution.
c) Risk from transporting the raw material through Singapore
According to the RIA, 65,000 tons per annum will go through Singapore in 4000 containers annually. Lynas has disclosed that the payload will be sealed inside double layered plastic bags. It will be transported as non-radioactive but as soon as it touches down in Kuantan, it is classified as radioactive. This is due to a legal loophole in Australia’s Dangerous Goods Act. The construction of the bags are not known. We do not know how robust they are. A spill may be disastrous to the environment.
d) Deterrent to Malaysia’s nuclear ambition
Due to its size, Singapore will probably not pursue nuclear power due to these power plants becoming strategic targets in times of war. This leads to Singapore being unfairly subjected to radiation risk from its neighbors’ nuclear ambitions. If Lynas is allowed to proceed, and the Malaysian public buy the “radiation safety” propaganda, nuclear plants will be next in line. If we stop Lynas now, the government will not dare to proceed to nuclear plants due to the political risks. Malaysia is capable of harnessing renewable energies and Malaysia’s wet climate is not suitable for nuclear repositories according to IAEA’s guideline  . The people of Malaysia and Singapore don’t need any more radiation risk and it is in Singapore’s interest that the Malaysian public remains averse to it.
Finally on 1/3/2012, a few days after the 15,000 strong green rally against Lynas, a Singaporean academia Professor ??? expressed doubt over the safety of the plant . Given Malaysia’s poor record in construction reliability, the most memorable one is the collapse of the roof of a newly constructed stadium in Terengganu, nobody trusts the incompetent Malaysia government to manage such a high risk venture.
We hope that the Singapore government agrees that the Lynas project is a reckless industrial experiment, and we hope that your honorable commissioner can do everything within your diplomatic power to persuade the Malaysian government to abandon this project.
Dr Lee Chee Hong (Technical Advisor for Himpunan Hijau 2.0)
Soo Jin Hou (Technical Advisor for Himpunan Hijau 2.0)
Lee Chean Chung (Himpunan Hijau 2.0 publicity chief)
Nasrun Amir Abdullah (Himpunan Hijau 2.0 event coordinator)
 “The Fear of a Toxic Rerun”, New York Times, by Keith Bradsher, June 29 2011.
 “Rare Earth Metal Refinery Nears Approval”, New York Times, by Keith Bradsher, Jan 31,2012
 “Phosphogypsum and Imported Drywall” from http://www.nuclearcrimes.org/phosphogypsum.php
 IAEA, “Near Surface Disposal of Radioactive Waste”, No. WS-R-1, 1999, pg 14.
This section outlines the justification of our assessment of LAMP:
a) Fundamental doubt in Lynas’ data
All regulatory scrutinises are qualified based on data provided by Lynas. Unfortunately, Lynas has not had any prior experience operating such a project. Nor does Lynas possess a pilot-scale plant which would generate an industries-proven data to corroborate claims. Therefore, the proposition by Lynas can be wholly disputed.
LAMP recently invited 4 members of the public and 3 local media reporters for an onsite visit/interview. During this visit Lynas admitted that most of the process data presented by it in the public domain have been obtained from results which have emerged by process simulation and laboratory analysis . It must be kept in mind that “Process simulation” is used for the design, development, analysis, and optimization of technical processes and is mainly applied to chemical plants and chemical processes. When this computational process model/simulation is built, some phenomena are simplified, and consequently some parameters are disregarded or distorted in comparison with reality. In addition, some of the relationships between the parameters could be neglected. [ref: Tanase Gh. Dobre, José G. Sanchez Marcano. “Chemical Engineering: Modelling, Simulation and Similitude”. John Wiley & Sons. pp 20. 2007].
What is far more valuable and far more accurate is actual data from real experience. Thus, if Lynas has actually been in this business they could have supplied real facts. Alternatively, Lynas could have provided the actual results from the Chinese experience. (To date, China is the world’s sole rare earth producer)
b) The radiation risk is greater than what Lynas and the Malaysian government are willing to admit
The radiation safety aspect of LAMP is legitimize by the IAEA’s review. However, increasing number of scientific literature points to a strong possibility that the IAEA model may have underestimated the risk of internal emitters, which are radioactive sources that are inhaled or ingested. This hypothesis is not merely based on correlation type studies, but is backed with sound scientific reasoning.
Thorium accumulates in the body. According to the “Radiological and Chemical Fact Sheets to Support Health Risk Analyses for Contamination”, about 0.02% to 0.05% of ingested thorium is dissolved in the bloodstream, and subsequently deposited mainly in the bones where the radioactive source becomes embedded within the bone tissue for a few decades . We are unsure exactly how much the body retains thorium from inhalation, but we know that “thorium is taken up in the body much more readily if inhaled rather than ingested”. True enough, the Radiological Risk Coefficient from inhalation is 450 times greater than that of ingestion .
Therefore if significant embedment of thorium is expected, the competing theory against IAEA’s ICRP model, the ECRR (European Committee on Radiation Risk) model must be considered because it takes into account the effects of thorium retention in the body. ECRR proponents reasonably believe that the ICRP formulation is wrong to dilute the radiation exposure from internal sources to the whole body, instead of confining it to the surrounding tissue only. So, the ECRR contends that the ICRP model has underestimated the real risk of low-level radiation.
In an email exchange between Lynas’ Radiological Safety Officer Nick Tsurikov and the editor for ECRR Chris Busby, Chris Busby suggested that the risk from internal thorium exposure should be 100 times greater than what IAEA says it is . The fact is, there is much uncertainty over the actual risk of low-level radiation within the scientific community. It is foolish for the Malaysian government to ignore the possibility that the ECRR might be right.
c) Effects to food chain
A serious contamination will cause the accumulation of radioactivity in the food chain.
Amazingly, Lynas agrees with us! According to their Radiological Impact Assessment (RIA), they computed through their radiation model that in 1558 years , the public exposure from drinking contaminated water and eating contaminated fish can reach 6.23 mSv/year, 6 times the allowable limit of 1 mSv/year, which we believe is an understatement because it is derived using the ICRP model. Thorium contaminated fish is not differentiable, it will not be easy to boycott fish the same way a recognizable product can be boycotted.
d) Construction reliability
New York Times on the 29th June 2011 in the article “The Fear of a Toxic Rerun” revealed cost-cutting practices as well as construction and design flaws of the plant. Some of them are “structural cracks, air pockets and leaks in many of the concrete shells for 70 containment tanks.” Then on 31st January 2012 in the article “Rare Earth Metal Refinery Nears Approval” reported that one of the key contractors to Lynas, AkzNobel pulled out due to quality concerns.
In response to these allegations, the Malaysian government tried half-heartedly to appease the public’s concern by obtaining safety verification from an unidentified registered engineer. No further information was given on the certification process . So, in addition to the uncertainty over the real risk from low-level radiation, we now also face the uncertainty over the impermeability of their waste ponds.
e) How rare earth processing should have been done
Lynas loves to boast that their project is approved in Australia also. Given Australia’s high environmental standard, if it is approved in Australia, why would Malaysians reject it? However, Lynas hid from the public that the Australian proposal was approved under extremely stringent conditions.
The table next page shows the conditions under the Australian proposal compared to LAMP.
Bury the waste at Mt Weld where it came from. No accumulation of waste at the refinery, the waste is shipped to the burial site immediately as they are produced.
No permanent waste disposal plan. Temporarily dump on-site.
To and from land transport between Mt Weld and the refinery site at Meenaar, 880 km apart.
Raw materials transported 1000 km by land and more than 4000 km by sea to Gebeng.
Nearest population center is 35 km away, with only 1,500 inhabitants.
700,000 people living within 35 km.
Waste diluted to 2.3 Bq/g.
Waste not diluted, radioactivity nearly 3 times higher at 6.1 Bq/g.
Impermeable ponds, progressively buried upon full.
Ttemporarily cover the waste by an “unspecified” method.
Located in the desert away from the aquifer. Annual rainfall 234 mm.
On reclaimed swamp land. Underground water just 0.95-3.5 m below surface. Annual rainfall 2,860 mm, area prone to flooding.
Total containment policy. All waste water evaporated and all left-over residue returned to Mt Weld.
500 tonnes/hour of water discharged to the South China Sea.
By looking at the huge discrepancies between the two, it is quite clear that the reason Lynas chose Malaysia is to dump its waste here.
 “Radiological and Chemical Fact Sheets to Support Health Risk Analyses for Contaminated Areas”, Argonne National Laboratory Environmental Science Division, March 2007. From http://www.ead.anl.gov/pub/doc/ANL_ContaminantFactSheets_All_070418.pdf
 “Radiation – general notes”, Nick Tsurikov, 25 Sep 2011, pg 20.
 “Radiological Impact Assessment of Advanced Materials Plant Gebeng Industrial Estate Kuantan, Pahang”, Nuklear Malaysia, Jun 2010, pg 63.
 “Radioactive Fallout from iPhones and Flat-Screen TVs?”, Kiera Butler, Mother Jones, 23 Feb 2012. From http://motherjones.com/environment/2012/02/rare-earths-lynas-malaysia