Sunday 31 December 2017

Lynas debts and liabilities to date (UPDATED)

2017 is coming to a close in slightly more than 24 hours. It is pertinent to reflect for a moment on what had taken place in terms of Lynas financial status as a going concern.

Lynas took out two separate loans from two creditors in 2011 and 2012 to complete both phase I and II of Lynas Advanced Materials Plant in Gebenr Industrial Estate (GIE).

They are:

1.The JARE facility ( Japan- Australia Rare Earth agreement backed by JOGMAC and Sojitz) worth US$ 225 millions secured against all assets owned by Lynas. It subscribed an additional US$25 millions worth of shares at the then prevailing price of AUD 2.12/share.

2.The Unsecured Convertible bonds worth US$225 millions from MT Kellet Capital Management LP,USA.

Both facilities went through two CDRS ( Corporate Debt Restructuring Scheme) in 2014 and 2016 and payment of all outstanding loans including the deferred interest payments are scheduled to be fully satisfied by September 2020.

Currently the JARE facility still has a balance of US$ 170 millions payable as at 21st Dec 2017 while the Unsecured Bonds has US$86.5 millions worth of bonds redeemable.

Interests due semi-annually will be accrued to the final settlement of both facilities in Sept 2020.

It is interesting to note that MT Kellet Capital Management LP has through seven partial conversions of bonds this year redeemed bonds worth a total of US$ 138.5 millions. This has added a total of 1.725 billion shares to Lynas' total shares in trade!

The consolidation exercise of 10:1 executed immediately after the last shareholders' AGM in late November has reduced the Lynas' total shares in issue to 563 millions shares.
SMSL PRESS STATEMENT ON 30/12/2017

A public statement on Issues remaining unresolved arising from the operations of Lynas Advanced Material Plant at Gebeng, Pahang.

The PDF (Permanent Disposal facility) for its radioactive Water Leach Purification (WLP) wastes.

Lynas Advanced Materials Plant (LAMP), a rare earth extraction plant located in Gebeng Industrial Estate (GIE) obtained its Temporary Operating License (TOL) in September 2012. In granting the TOL, the regulating authorities required LAMP to submit a detail plan on the selection of the location and management of its radioactive wastes in a Permanent Disposal Facility (PDF) within 10 months of its operations. According to the regulating authorities, the Atomic Energy Licensing Board (AELB) , it was fulfilled conceptually but no mention had been made on the location.

Since then announcements had been made ‘periodically’ by Lynas that they have found a way to recycle the radioactive wastes into road base aggregates; soil enhancers, etc and experiments had been ongoing thus negating the necessity to identify a PDF for the said radioactive wastes. These reports and announcements can be read in various online and print media and their quarterly submissions to the Australian Stock Exchange (ASX). (Just Google PDF)

The latest being the claim that a soil enhancer (conditioner) called ‘Condisoil’ has been successfully formulated from the mixture of all three types of solid residues inclusive of the radioactive WLP residues for use in agriculture! All previous attempts and claims to recycle the radioactive WLP evaporated into thin air!

In last July’s Parliamentary sittings, all members of Parliament were informed by the Science, Technology and Innovations Minister Datuk Seri Wilfred Madius Tangau that the recycled product ‘ Condisoil’ had yet to receive SIRIM’s green light. (http://www.thesundaily.my) He also revealed that the mixture of ‘Condisoil’ was made up of 1 part of WLP; 2 parts of NUF (Neutralization Underflow) and 7 parts of FGD (Flue Gas Desulfurization) residues. Meanwhile the Lynas Management had gone to town to declare that the successful development of this ’new product’ has resolved the requirement of finding a location and building the PDF to safely manage the radioactive WLP wastes! (Sin chew Jitpoh 19th July 2017)

We the residents of Kuantan are appalled by such irresponsible claims!

Here are the reasons:

1. In order to better understand the components of the soil enhancer called ‘Condisoil’ we have to first take a look at the chemical compositions of these constituents. Attached are the chemical make-up of each category of these three residues produced during the extraction of rare earth oxides (compounds) at LAMP. ( See attachments 1; 2 & 3)

2. From the chemical compositions listed ( provided by Lynas in its Radioactive Waste Management Plan (RWMP) ), it is obvious that WLP carries with it many chemicals that are of little or no use to plants and the most damaging part of all is its content of the radioactive Thorium and Radium!

3. Any attempt or experiment to mix these ‘residues’ would have to take into serious consideration on overcoming technical difficulties in the measurement of correct mixture because each of these residues, produced in moist cake forms, contains 40-45% moisture.

4. A correct or accurate mixture of these residues would invariably involve a preliminary step of drying and this action attracts tremendous costs in fuel expenditure which makes the attempt economically non-viable!

5. To entrust and seek approval from SIRIM on Condisoil’s safe usage is totally misplaced! SIRIM is the body that appraises and evaluates proposed industrial standards’ drafted by relevant professional bodies before they become Malaysian Standards. Does this mean should SIRIM approve ‘Condisoil’, it would become the Malaysian Standard for recycled radioactive wastes? How would other industries churning out radioactive wastes view this? They too would have the liberty of ‘mixing’ their radioactive wastes, giving it a fancy name and pass it off as a safe recycled industrial byproduct?

6. The proposed mixture of 1:2:7 of WLP: NUF: FGD will leave behind large quantities of unused radioactive WLP wastes for lack of FGD to go with it to create the so called ‘ Condisoil’.

From the data provided by Lynas in their RWMP,for every ton of REO ( Rare Earth Oxides) produced there will be an accompanying 13.41 tons of solid residues produced ; out of which 2.85 tons will be WLP; 7.93 tons NUF and 2.63 tons FGD. There are more WLP produced than FGD and yet their requirement in the mixture is 1:7. Mathematically it can be worked out that with all the FGD produced and used in formulating the Condisoil, only 13.18% of WLP will be consumed for this purpose! May we know what Lynas intends to do with the remaining 86.82% of the radioactive WLP? Don’t they require a PDF to safely store it?

Ending September 2017, there is an estimated 138,820 tonnes (dry weight) of WLP residues generated and kept at the back of the LAMP! If Lynas were to successfully utilize all their FGD (127,720 tonnes) there will a balance of 120,523 tonnes of WLP in the residue storage facility in LAMP!

Lynas projected a greater quantum of REO production for the December Quarter this year and the coming years. How much more WLP will be added onto this existing pile of radioactive residues? Are they ready to act responsibly as a corporate citizen of this country by IDENTIFYING A SUITABLE SITE FOR THE PDF OR are they going to continue to hide behind their wonder industrial byproduct called ‘Condisoil’?

Just this month Lynas has spent quite a substantial amount of ringgits by taking out a 3 half-page coloured advertisements in a local newspapers while the mandatory safe deposits of USD 50 millions are yet to be fully satisfied fully according to agreed schedule!

If the regulating authorities, the AELB, believed that Condisoil is a viable solution to the management of the radioactive WLP waste , then perhaps the payment of this safe deposit may not be necessary!

It is obvious that the issue of resolving the radioactive waste safely by Lynas through ‘Condisoil’ is but an attempt to pull a wool over people’s eyes! If left unchecked, our beloved land will be littered with radioactive residues from LAMP!

Statement by Save Malaysia Stop Lynas Committee.






Here comes the NUF chemical compositions :
Composition ...................Weight %
FePO4.5H2O...................... -
Fe2O3................................. -
Fe(OH)3.............................. -
Al2O3.................................. -
Al (OH)3.............................. -
Al2 (SO4)3.16H2O.............. -
CaSO4. 2H2O..................... -
CaSO4.................................73.5
Ca(OH)2.............................. -
CaCO3................................ 4
CaCO3.2H2O...................... 2
CaC2O4............................... -
Ca3(PO4)2.4H2O................ 1.5
SiO2..................................... -
MgF2.................................... -
Mg(OH)2.............................. 17.5
MgCO3.3H2O....................... -
MgSO3.7H2O........................ -
Mg3(PO4)2.5H2O.................. -
LaPO4................................... 1.5
LaPO4.4H2O.......................... -
La(OH)3 ..................................-
La2(CO3)3.5H2O.................... -
CePO4.4H2O.......................... -
Ce(OH)3.................................. -
Ce2(CO3)3.5H2O.................... -
PrPO4.4H2O............................ -
Pr(OH)3.................................... -
Pr2(CO3)3.5H2O...................... -
Nd(OH)3.................................... -
Nd2(CO3)3.5H2O...................... -
NdPO4.3H2O............................. -
ThO2.......................................... -
Th(PO3) 4.4H2O........................ -
CaUO4....................................... -
Radiations.................................. 0.52Bq/g

( Total Activity concentration of Th-232 and U-238 decay chains)
The concentration of radionuclides in the rare earth products should be very low (< 0.2 Bq/g)

The FGD Chemical Compositions :

Composition...................... Weight %
FePO4.5H2O----------------------Nil -
Fe2O3-------------------------------Nil -
Fe(OH)3---------------------------- Ni l-
Al2O3--------------------------------Ni l-
Al (OH)3-----------------------------Nil -
Al2 (SO4)3.16H2O---------------Ni l-
CaSO4. 2H2O---------------------95
CaSO4 ------------------------------Ni l-
Ca(OH)2----------------------------- 4
CaCO3------------------------------- 0.1
CaCO3.2H2O-----------------------Nil -
CaC2O4------------------------------Ni l-
Ca3(PO4)2.4H2O------------------Nil -
SiO2-----------------------------------0.6
MgF2----------------------------------0.3
Mg(OH)2----------------------------- Nil -
MgCO3.3H2O----------------------- Nil -
MgSO3.7H2O----------------------- Nil -
Mg3(PO4)2.5H2O------------------ Nil -
LaPO4--------------------------------- Nil -
LaPO4.4H2O------------------------ Nil -
La(OH)3------------------------------- Nil -
La2(CO3)3.5H2O------------------- Nil -
CePO4.4H2O------------------------ Nil -
Ce(OH)3------------------------------- Nil -
Ce2(CO3)3.5H2O------------------- Nil -
PrPO4.4H2O------------------------- Nil -
Pr(OH)3-------------------------------- Nil -
Pr2(CO3)3.5H2O-------------------- Nil -
Nd(OH)3------------------------------- Nil -
Nd2(CO3)3.5H2O------------------- Nil -
NdPO4.3H2O------------------------- Nil -
ThO2------------------------------------ Nil -
Th(PO3) 4.4H2O--------------------- Nil -
CaUO4---------------------------------- Nil -
Radiations------------------------------ 0.47 Bq/g

( Total Activity concentration of Th-232 and U-238 decay chains)

Here are the Chemical compositions of each category of the residues :
Chemical Composition of the Residue Streams

Composition WLP......Weight %
FePO4.5H2O ------------ 54
Fe2O3 ----------------------- 5.5
Fe(OH)3--------------------- 4
Al2O3 -------------------------0.1
Al (OH)3 ----------------------3
Al2 (SO4)3.16H2O---------1.7
CaSO4. 2H2O---------------3.5
CaSO4 ------------------------0.9
Ca(OH)2 ----------------------0.1
CaCO3 ------------------------Nil
CaCO3.2H2O----------------0.1
CaC2O4 ----------------------Nil
Ca3(PO4)2.4H2O ----------2
SiO2 ---------------------------8
MgF2 --------------------------Nil
Mg(OH)2----------------------0.03
MgCO3.3H2O--------------- 2.5
MgSO3.7H2O--------------- 6.5
Mg3(PO4)2.5H2O---------- 0.2
LaPO4 ------------------------ Nil
LaPO4.4H2O---------------- 2
La(OH)3 ----------------------0.1
La2(CO3)3.5H2O-----------0.2
CePO4.4H2O --------------- 3
Ce(OH)3----------------------- 0.1
Ce2(CO3)3.5H2O----------- 0.4
PrPO4.4H2O------------------0.4
Pr(OH)3-------------------------0.01
Pr2(CO3)3.5H2O-------------0.03
Nd(OH)3------------------------ 0.05
Nd2(CO3)3.5H2O------------ 0.1
NdPO4.3H2O------------------1.3
ThO2-----------------------------1000ppm
Th(PO3) 4.4H2O--------------1200ppm
CaUO4 ------------------------- 30ppm
Radiations----------------------62.29

(Total Activity concentration of Th-232 and U-238 decay chains) Bq/g


With this detailed breakdown of WLP's Chemical compositions, one will be able to determine its 'synergistic' if any role in complementing the FGD and NUF in the 'Condisoil'(2).





Monday 11 December 2017

To most of us the laymen, the chemical composition of each category of residues does not carry much significance in our understanding of how eco-toxic or otherwise they may be. We are more concerned on how the combination of WLP; NUF and FGD in the ratio 1:2:7 could enhance the efficacy of the Condisoil.

The combination ratio seems to demonstrate an agenda behind it i.e. to achieve an end result of radionuclide reading below 1 Bq/g so that it could be classified as non-radioactive and passed as a clean waste. This will remove WLP from the regulatory control of AELB and the final mixture will be placed under the purview of DOE.

It really does not matter if the 'Condisoil" is marketable. If it is not then it can be used in municipal landfills and there would not be a need to build a PDF for it!

Here are the Chemical compositions of each category of the residues :

Chemical Composition of the Residue Streams
Composition WLP......Weight %
FePO4.5H2O ------------ 54
Fe2O3 ----------------------- 5.5
Fe(OH)3--------------------- 4
Al2O3 -------------------------0.1
Al (OH)3 ----------------------3
Al2 (SO4)3.16H2O---------1.7
CaSO4. 2H2O---------------3.5
CaSO4 ------------------------0.9
Ca(OH)2 ----------------------0.1
CaCO3 ------------------------Nil
CaCO3.2H2O----------------0.1
CaC2O4 ----------------------Nil
Ca3(PO4)2.4H2O ----------2
SiO2 ---------------------------8
MgF2 --------------------------Nil
Mg(OH)2----------------------0.03
MgCO3.3H2O--------------- 2.5
MgSO3.7H2O--------------- 6.5
Mg3(PO4)2.5H2O---------- 0.2
LaPO4 ------------------------ Nil
LaPO4.4H2O---------------- 2
La(OH)3 ----------------------0.1
La2(CO3)3.5H2O-----------0.2
CePO4.4H2O --------------- 3
Ce(OH)3----------------------- 0.1
Ce2(CO3)3.5H2O----------- 0.4
PrPO4.4H2O------------------0.4
Pr(OH)3-------------------------0.01
Pr2(CO3)3.5H2O-------------0.03
Nd(OH)3------------------------ 0.05
Nd2(CO3)3.5H2O------------ 0.1
NdPO4.3H2O------------------1.3
ThO2-----------------------------1000ppm
Th(PO3) 4.4H2O--------------1200ppm
CaUO4 ------------------------- 30ppm
Radiations----------------------62.29


( Total Activity concentration of Th-232 and U-238 decay chains) Bq/g 


With this detailed breakdown of WLP's Chemical compositions, one will be able to determine its 'synergistic' if any role in complementing the FGD and NUF in the 'Condisoil'(2).


The FGD Chemical Compositions :
Composition...................... Weight %
FePO4.5H2O----------------------Nil -
Fe2O3-------------------------------Nil -
Fe(OH)3---------------------------- Ni l-
Al2O3--------------------------------Ni l-
Al (OH)3-----------------------------Nil -
Al2 (SO4)3.16H2O---------------Ni l-
CaSO4. 2H2O---------------------95
CaSO4 ------------------------------Ni l-
Ca(OH)2----------------------------- 4
CaCO3------------------------------- 0.1
CaCO3.2H2O-----------------------Nil -
CaC2O4------------------------------Ni l-
Ca3(PO4)2.4H2O------------------Nil -
SiO2-----------------------------------0.6
MgF2----------------------------------0.3
Mg(OH)2----------------------------- Nil -
MgCO3.3H2O----------------------- Nil -
MgSO3.7H2O----------------------- Nil -
Mg3(PO4)2.5H2O------------------ Nil -
LaPO4--------------------------------- Nil -
LaPO4.4H2O------------------------ Nil -
La(OH)3------------------------------- Nil -
La2(CO3)3.5H2O------------------- Nil -
CePO4.4H2O------------------------ Nil -
Ce(OH)3------------------------------- Nil -
Ce2(CO3)3.5H2O------------------- Nil -
PrPO4.4H2O------------------------- Nil -
Pr(OH)3-------------------------------- Nil -
Pr2(CO3)3.5H2O-------------------- Nil -
Nd(OH)3------------------------------- Nil -
Nd2(CO3)3.5H2O------------------- Nil -
NdPO4.3H2O------------------------- Nil -
ThO2------------------------------------ Nil -
Th(PO3) 4.4H2O--------------------- Nil -
CaUO4---------------------------------- Nil -
Radiations------------------------------ 0.47 Bq/g
( Total Activity concentration of Th-232 and U-238 decay chains)


Here comes the NUF chemical compositions :
Composition ...................Weight %
FePO4.5H2O...................... -
Fe2O3................................. -
Fe(OH)3.............................. -
Al2O3.................................. -
Al (OH)3.............................. -
Al2 (SO4)3.16H2O.............. -
CaSO4. 2H2O..................... -
CaSO4.................................73.5
Ca(OH)2.............................. -
CaCO3................................ 4
CaCO3.2H2O...................... 2
CaC2O4............................... -
Ca3(PO4)2.4H2O................ 1.5
SiO2..................................... -
MgF2.................................... -
Mg(OH)2.............................. 17.5
MgCO3.3H2O....................... -
MgSO3.7H2O........................ -
Mg3(PO4)2.5H2O.................. -
LaPO4................................... 1.5
LaPO4.4H2O.......................... -
La(OH)3 ..................................-
La2(CO3)3.5H2O.................... -
CePO4.4H2O.......................... -
Ce(OH)3.................................. -
Ce2(CO3)3.5H2O.................... -
PrPO4.4H2O............................ -
Pr(OH)3.................................... -
Pr2(CO3)3.5H2O...................... -
Nd(OH)3.................................... -
Nd2(CO3)3.5H2O...................... -
NdPO4.3H2O............................. -
ThO2.......................................... -
Th(PO3) 4.4H2O........................ -
CaUO4....................................... -
Radiations.................................. 0.52Bq/g


( Total Activity concentration of Th-232 and U-238 decay chains)


The concentration of radionuclides in the rare earth products should be very low (< 0.2 Bq/g)


All figures above are from the RWMP.




Continuation

20. Now that the Condisoil (2) formula has been approved by SIRIM, it will go under the supervision and departmental control of DOE.

Let's take a closer look at what challenges that will be encountered by Lynas in putting into practice the utilization of all three categories of residues as Condisoil.

20.1 : Natural state of residues.

i) All the three categories of solid residues, WLP; FGD and NUF are produced in moist cake forms, each consisting of 55% (FGD & NUF) and 60% (WLP) of solids respectively. They have a moisture content of 40-45%.

ii) They are stored in separate cells in the RSFs.
20.2 Volume of each category of solid residues according to designs :
22.2.1 based on the initial design case (IDC) of the plant with a processing capacity of 11,000 tonnes, the residues produced will be as follows:

Tailings IDC (Wet t/a) % Solids IDC (Dry t/a)
FGD 53,560 55 29,500
NUF 161,820 55 89,000
WLP 53,333 60 32,000

20.2.2 With Phase 1 and 2 in full operations, the residues produced will be doubled:
Tailings FOS (wet t/a) % Solids FDC (Dry t/a)

FGD 109,554 55 58,920
NUF 330,995 55 177,800
WLP 109,090 60 64,000

(Note : FOS- Full Operating Stage ; FDC -Future Design Case)

20.2.3 How much of these residues are already been produced?

According to published production figures of REO separated at LAMP since June 2013 * (Note 1)
Ending September 2017 :

Tailings Total tonnage (wet) Total tonnage (Dry) Dry

FGD 232,327 127,780.
NUF 701,086 385,597.
WLP 231,366 138,819.

(Note 1: LAMP obtained the TOL in September 2012. It took 9 months (Sept 2012-June 2013) to commission and began with small amounts of production)

20.4 How much of these residues were used in the research program?

20.4.1 : In the attempt to extract Thorium from the WLP residues conducted by UKM , only a small sample was collected from LAMP.

20.4.2 ; In the experiments conducted with the use of FGD and NUF as soil conditioner ( Condisoil 1) a total of 1 ton was utilized. This was revealed by the DOE. This included the field trials with several crops over a certain period of time.

20.4.3 :Experiments conducted before the TOL was issued as described in my earlier posts did not come from residues generated since 2013.

20.5 : Main issues regarding the implementation of the 'Condisoil (2)' project :

20.5.1 :With such high moisture content in each category of residues, how can accurate measurement of proportions be observed without first drying them?

20.5.2 : If the residues need to be prepared in a reasonable state of dryness, with such large volumes how much fuel costs will be incurred and would this negate its viability financially?

20.5.3 :It is useful to keep in mind that the approved Condisoil (2)) formula is a combination of WLP, NUF and : FGD in the ratio of 1 : 2 : 7,. With the relatively differing volumes of each of these residues produced at LAMP , the combination of the mixture will bring about a large a shortfall of supply for FGD while leaving a large balance of WLP.

20.5.4 : Under this scenario Lynas would still need a PDF to ensure the balance radioactive WLP residues are stored in specially designed dedicated storage cells!Thus a PDF is still needed!

20.6 : Who will be the buyers or clients of this 'Condisoil (2)" as it contained radioactive WLP? Or would the approved 'Condisoil'(2) be a pretext for Lynas to evade the issue of locating a site and the construction of the PDF?

These are issues that Lynas' web site did not answer. Neither is the management willing to meet the stakeholders on these issues of concern !

If this Condisoil issue is not supervised and regulated closely, Malaysian soils and waterways will be the final bearer of this diluted radioactive toxicity!
Continuation

18. The plans and time frames described in my last posting on the reuse of the residues would virtually give all stakeholders and residents of Kuantan an assurance that everything would be well and good . That piece of information was displayed for public review in Dec 2011.

It is now 2017. As can be seen none of that planned and described had culminated in the commercialization of the residues. They did tried but non seemed to be commercially viable!.
When the Temporary Operating License (TOL) was due for renewal, they had revised the RWMP with a claim " they are seeking approval from the authorities to build an experimental road with the WLP residues for demonstration and assessment! "

They have also stated that " they had gained the approval from a customer and is preparing to make the first commercial export of Neutralization Underflow (NUF) product. Negotiation are ongoing for further commercial shipments. Lynas has also finalized the specifications for three granulated products for use in broad-acre trials!"

In July this year we paid a visit to the Pahang DOE and was informed that Lynas had formulated a soil conditioner called 'Condisoil" with FGD and NUF residues. They planned to start its production on commercial scale at the end of the month but for some reasons unknown it was shelved or aborted. Then came the controversial claim by Lynas that a new 'Condisoil" with the inclusion of WLP in its formulation had already been approved for use by the authorities concerned. This was disputed by Kuantan MP Fuziah Salleh based on the answer she obtained in Parliament from the Minister of MOSTI.

As ca be seen all those original plans designed for the recycling of LAMP's residues into Synthetic Materials Products did not materialize. The final practical way to recycle them would be to dilute and water down the radioactivity of the WLP residues with the addition of the other two residues. Killing 3 birds with one stone!!!

What great efforts in their research!

They revealed that the research so far had costed them RM7 million!

You might have a nagging suspicion that were the plans drawn up specifically for the authorities concerned to " facilitate" the approval of their Milling A license (TOL)? How could they propose to recycle the three categories of residues into various commercial industrial products when they had not started operating?

This is why our country is a safe haven for fugitive industries that were disallowed to be built in their countries of origin !

Are we looking at more polluting industries of this nature coming to our shores?

19. As can be seen despite all the proposed plans by Lynas to recycle the three categories of solid residues according to their time frames, they ended up in a single recycled product called "Condisoil". And according to feedback from our MP, SIRIM has given its nod and it is now under the purview of the DOE.

A brief recap on the original recycling intent or plan for each of the solid residues will help understand better the whole issue on recycling of residues produced by LAMP.
Based on reports of the research conducted, WLP was intended for road base or interlocking block pavers.

The NUF with its Mg content is more suited to be turned into a soil conditioner to improve degraded or infertile soils.
The FGD has been identified as a suitable material for the manufacture of plaster board and cement.

After the visit by IAEA Review team in 2014,the two solid residues NUF and FGD with radioactivity below 1 Bq/g were dropped from the regulatory control of AELB . They were classified as clear waste and placed under the DOE's purview. This is why during our visit to the state DOE office, we were told by the Director that the Condisoil (1) experiment conducted used only FGD and NUF.

One may ask why WLP was not included in the formulation of Condisoil (1) then. Its simple. WLP has a radioactivity of 7.98 Bq/g ( from The Malaysian Journal of Analytical Sciences, Vol 18 No1(2014):221-225) thus is placed under the regulatory control of AELB!

This also explains why the new formulation of "Condisoil (2)" has a combination ratio of 1 part WLP, 2 parts of NUF and 7 parts of FGD! The main 'plot' (scheme) behind this combination is to ensure that the resultant mix will have a radioactivity reading of less than 1 Bq/g so that it too could be removed from the regulatory control of AELB. It could then be allowed to be used for municipal landfills or in this case a non toxic, non radioactive soil conditioner!

21. How much in total the solid residues that will be generated by LAMP which is designed to operate for 8000 hrs (333.33 days X 24 hr) per year for 20 years?
Answer : 5,864,240 tonnes (dry weight)
Translated into wet weight the total will be 10,471,857 tonnes.

Before they could be 'recycled' ,sufficient storage space would have to be found to keep them ( currently behind the plant) while observing the regulatory requirements under the newly promulgated ( after the public hearing by IAEA team in May 2011) Atomic Energy Licensing (Radioactive Waste Management) Regulations, 2011 which came into force on the 16th of August 2011.

Wonder if should the residues generated quickly exceeded the recycling capacity and storage space available, a repeat of incidents like what took place in the ARE 30 years ago will befall the destiny of Kuantan and folks around Balok?





Continuation

15.This is how Lynas proposed to temporarily store the solid residues:

- During the operation of LAMP, an onsite residue storage facility (RSF) will be constructed for the storage of the FGD, NUF, and WLP;

- These cells are collectively described as the Residue Storage Facility ( RSF ) and will be utilized for temporary onsite storage of the residues during the operational life of the LAMP.

- Upon plant closure after 20 years, any remaining residue within the RSF will be transported offsite to a permanent disposal facility (PDF) for long term storage . At the time of report (RWMP) preparation (Dec 2011) , the proposed site for the PDF had not been identified.

- The design storage capacity for the RSF is approximately 5 years for each of the respective residue streams, namely, the FGD, NUF and WLP. The RSFs will be constructed in 2 phases. In the first phase, the RSFs will be constructed to cater for a storage capacity of 1.5 years for all 3 residues. In phase 2, the RSFs will be expanded by constructing new engineered cells to cater for an additional 3.5 years worth of storage capacity.

- The total land capacity available at the LAMP site is 5 years worth of production of each of the 3 residues, namely. FGD, NUF and WLP, estimated at 1,635,000 m3.

- Available capacity for Phase I ; 127,000m3 ( 1.5 years of residue storage capacity )

- Available capacity for Phase II ; 1,508,000 m3 ( 3.5 years of residue storage capacity )

- This is based on the projected annual production of 22,500 tonnes of REO.

- LAMP has been in operation for 5 years . The total REO produced over the effective 4 years (LAMP took 9 months to commission before its first production) added up to 44,274 tonnes , a mere 56% of its targeted capacity.

16. This is what they presented to our authorities on the management of the residues :
-" Based on the promising outcome of research on the commercialization of the 3 residues, Lynas assumes that FGD and NUF will be sold (removed off site ) after obtaining approval from the DOE on the re-use of these 2 streams within 6 months of operation. Therefore , all storage capacity available under Phase 1 will be consumed by the WLP residue by month 21." ( From RWMP report)

- This is not happening. After 5 years of operation, Lynas is still struggling to find a solution to the increasing quantities of the 3 streams of solid residues generated each day despite their claims that research on the reuse of the NUF and FGD started since 2009)

- "Beyond month 21, the WLP residue will be stored within the capacity made available for the second phase which will be sufficient until month 200 (17 years) on wet basis (or 20 years on dry basis). "

- Will the 'Condisoil" help save the day? Obviously with the formula they proposed and experimented on by mixing the WLP; FGD and NUF in the ratio of 1 :2 :7, the proposed need to store the remaining unused residues in a PDF will still be needed especially for the balance WLP)

- "In the unlikely event that the WLP is not able to be commercialized, these residue streams will be stored onsite within the RSF. As the maximum design storage capacity of the RSF is approached, the radioactive residue (WLP) will be removed from the site in campaigns to the PDF approval by AELB. Lynas proposes to initiate the site selection exercise for the PDF after two years of operation or earlier, as deemed necessary"

- (It has been stated in RWMP that the plan was to locate the PDF in the state of Pahang. Of course this is subject to the approval of the regulating authorities and the state government. But until this date Lynas has yet to declare openly they have found a suitable site for the PDF.)

- Now with hyped 'Condisoil' project, it is to be expected that the PDF issue will be put in the back burner for sometime to come.

- Recently there were reports that the certain industry was approached to utilize the FGD / NUF residues as an input for their product . This was turned down despite earnest efforts to convince the industry players that the two residues have been removed from the regulatory control as scheduled waste thus safe to be used as a component of their product.

- The latest was the issue raised by Kuantan MP YB Fuziah in the current Parliamentary sitting that LAMP's residues are to be used to rehabilitate the hollowed-out land in Bukit Goh as a result of bauxite mining.
-It is now clear that frantic efforts are in progress to find a sustainable use for the residues churned out by LAMP.

17. This is what they told our regulating authorities how the residues are to be turned into Synthetic Mineral Products (SMP) :

- "Research & Development efforts are ongoing for the development of the SMPs from the three residue streams, FGD, NUF and WLP."
- Key products or applications of focus are:

• Synthetic gypsum for plaster board manufacture;
• Gypsum for cement manufacture;
• Gypsum materials for road base formulation;
• Mg gypsum fertilizers for plantations, corps, and soil remediation; and
• Carbon-enriched Mg gypsum fertilizer will potential to rejuvenate BRIS and acidic soils.

- It even provided the time frames for commercialization of products :

FGD - Synthetic Gypsum

2012 -Qualify Product with customer
- Commission Drying Plant and commence FGD sales in Q4 2013 -100% sales of FGD
- Evaluate feasibility of reclaiming FGD from Storage Facility
- Trial addition into Fertiliser to supplement NUF 2014-2015
- FGD may go into Fertiliser for better return

NUF - Mg Rich Gypsum 2012
-Fertiliser – Soil Conditioner

• Q1 – Lab Granulation Trials & Post Studies completed
• Q4 – Granulation Pilot Trials & Field Studies
• Q3 – Supply contracts locked in for MgCaSO4 granule
• Carbon feasibility completed
• Register Projects for Carbon Credits 2013 -
• Q1 – Start-up MgCaSO4 plant and sales to Australia, Malaysia and Indonesia
• Extensive field trials with Carbon Mg gypsum with end-users
• Lock in Lols with Carbon Mg gypsum End-Users
• Q4 Initiate carbonization (pyrolysis) project with key partners 2014-2015
• Start-up on Carbon Mg gypsum product
• Continue with MgCaSO4 granule but increasingly switch to carbon product
• Farming and sell carbon credits WLP-IPG ( Iron Phospho Gypsum)2012-2012
-• Construction Material R&D: formulation testing for road base and paver manufacture 2013
Continued R&D:
• Strength improvement in concrete products
• WLP granulation
• Demonstration projects for applications:
> Road construction
> Pre-cast Interlocking pavers
> Concrete Products

2014-2015
• Ongoing demonstration followed by commercialization
What an impressive description and plans to turn all the residues into SMPs!
Our government is either totally ignorant of what others before Lynas has failed to utilize similar wastes ( residues ) and turn them into industrial ' byproducts' or helping to justify Lynas' presence here by allowing thousands of tonnes of radioactive wastes to be generated and deposited on our land?

Let's see what others had said about phospho gypsum from FGD :
"Some types of FGD gypsum are generally considered unsuitable for use in gypsum board due to potential environmental hazards; for example, phosphogypsum may contain radon and radio nuclides.
Members of the Gypsum Association do not use phosphogypsum to manufacture any gypsum-based product"

FGD and NUF contain radionuclides and are thus unsuitable for recycling into gypsum boards. This is perhaps why Lynas has not brought up the subject again since they began operating.

Continuation

12. Here is how LAMP is designed to function:

- it 'cracks and separates' Lanthanide Concentrate ( Rare Earth Ores) to obtain Rare Earth Oxides in carbonate and oxides forms for various light and heavy rare earth elements.;

-t he overall efficiency of the various processes or cracking and leaching; extraction and post treatment is around 86.09% of the total THROUGHPUT;

- It is designed to operate 24/7 for 8,000 hours per year which works out to 333.3 days.

- The scheduled shipment of Concentrate was slated to begin in July 2009. It was delayed until Nov 2012.

- Initial annual shipment quantities is 32,407 tpa (dry) with long term annual shipments amounting to 64,800 tpa (dry) for 2010 onwards. ( this was realised in 2014).

- All concentrate are transported in 2t bags in sea container from Mt Weld to Fremantle port by road and rail ; a distance of more than 1,000 km.; 1,007.0 km to be exact.

- They are then shipped in sea containers of 20 tonnes units to Kuantan Port.

- The content of these units then undergo processes as
described below: ( this will give you an inkling on how REO are produced) :

i) Concentrate will first be mixed with concentrated sulphuric acid before being pumped into the cracking kiln.The mixture of acid to dry concentrate is 1.6:1 with a residence time of 20 minutes.The slurry will reach a temperature of 140 to 180 degrees C.

ii) Once the slurry is in the cracking rotary kiln, it will be subjected to a calcine temperature of 650 degrees C for 150 minutes. The feed gas temperature could reach 850-900 degrees C while discharge gas temperature is 250-300 degrees C.
The waste gas produced is scrubbed to filter off the sulphur dioxide (SO2), sulphur trioxide (SO3) and suspended particles to comply with Standard C of the Environmental Quality ( Clean Air) Regulations, 1978.

Of these pollutants only the particulates and sulfur trioxide are regulated emission limits under Std C. ( Under Std C, solid particles emitted at any point of any smoke of any kind before admixture with air should be 0.4 grams in each normal cubic metre of effluent gas.)

The scrubbing process yields the first solid residue FGD ( Flue Gas Desulfurisation)

13. Now that the extraction process of Rare Earth Oxides has been explained in great details, let's examine the claim that Lynas Advanced Materials Plant (LAMP) is a modern high tech plant as hyped by their PR spinners.

As can be seen, the raw material from Mount Weld, Western Australia, contains various light and heavy rare earths . They have to be converted into soluble salts in an aqueous media ( a liquid medium) before they are precipitated as RE salts in Chloride, oxide or carbonate forms.

The Lynas Advanced Materials Plant (LAMP) is basically designed to do just that. It uses various processes and chemicals to do the job. It began by breaking up the ore (lanthanide concentrate) containing various rare earths by dissolving them in concentrated sulphuric acid and then subject it to near melting point temperature treatment before leaching the soluble metals in a liquid medium. Each individual Rare Earth is subsequently precipitated with different reagents to achieve a certain level of purity in a process called solvent extraction. That just about sums up what LAMP is designed to do.

Can this simple routine chemical plant be called a modern high tech plant? It sounds more like an exaggeration than the truth. For this our government granted LAMP a 12 years tax exemption! It is rather ought because normally a plant with pioneer status will be granted a 5 year or 10 years tax relief but 12 years? Perhaps the MOF can explain the rationale behind the exception.

14. Today marks the 5th year of an infamous event that took place under the cover of the nite with the escort of our police . It was the first shipment of the rare earth ores from Mt Weld to LAMP. You can read all about it in the post by Stv Zhong Liang below.

Before this, information was not available anywhere on the rare earth ores that formed the primary feedstock for Lynas' extraction plant in LAMP. Now with the help of various documents made available through the process of law and public pressure,we can now take a closer look at the ores and their byproducts after they have undergone the extraction process.

The feedstock ( rare earth ores) are mined and concentrated at Mt Weld mine in Western Australia. The long term annual shipments will deliver 64,800 tonnes of dry Lanthanide Concentrate to LAMP.

At LAMP , the imported Lanthanide Concentrate will undergo cracking , separation and product finishing and generate 3 major solid residue streams . They are namely the FGD ( Flue Gas Desulfurisation); WLP (Water Leach Purification) and NUF ( Neutralisation Underflow) residues.

All these 3 streams of solid residues are generated in moist cake forms which have a moisture content of 40-45%. According to the initial design of LAMP, the plant will generate 53,560 wet tonnes of FGD; 161,820 wet tonnes of NUF and 53,333 wet tonnes of WLP. At full operating stage the total tonnage generated for each stream will be doubled!

All these streams of residues were originally placed under the regulatory control of AELB. The FGD and NUF residues contain very low levels of radionuclides. This prompted the IAEA review team to recommend that a criteria be developed by AELB to enable them to be removed from their regulatory purview.



LYNAS' LAMP (UPDATES)

Here is a full recap on the Advanced Material Project of Lynas and its attending management plan for the residues produced at LAMP . The proposed requirement of a PDF (Permanent Disposal Facility) and the recycling of LAMP's residues into industrial byproducts can be traced to events unfolding after the residents of Kuantan launched a big protest against the project. This rather long description will give you a holistic perspective on the controversy surrounding this rare earth project. It is written for the record and the benefit of all interested in the issue.

1. The Basis of Design for LAMP described in great details on the proposed Advanced Material Project of LAMP. The document concerned is marked as Document No. 4219298-000-GE-BD-001-0G.

2.'The project involves the development of a mine and concentrator plant in Western Australia and a processing plant in Malaysia which will produce high purity lanthanide compounds.'


3.'The Advanced Material Project will consist of two separating plants, each with a number of processing areas:
-Concentration plant , Mt Weld , Western Australia:
i) Crushing and grinding;
ii) Flotation;
iii) Concentrate and handling;
iv) Water treatment and residue management; and
v) Utilities.

- Advance Materials Plant, Gebeng, Pahang, Malaysia:
a) Cracking;
b) Waste gas treatment;
c) leaching ( primary, secondary, tertiary);
d) Upstream extraction;
e) Downstream extraction;
f) Post treatment;
g) Utilities;
h) Water treatment and residue management; and
i)Off-plot.



4. The design for the Advanced Materials Plant was first issued for client and internal review in March 2007. Originally the plant was to be sited in Telok Kalong Industrial park in Kemaman.
Before that Lynas actually planned to build the plant in Shandung Province , China. It was aborted because China imposed an export restriction on how the processed Rare Earth Oxides (REO) are to be marketed.

5. The design was formally approved by Lynas in March 2010. This timeline demonstrated a phenomena that the plant in Gebeng was constructed on an ongoing design and built platform. The construction started in 2007.

6. The Concentration plant at Mt Weld will produce intermediate Lanthanide Concentrate which will be the feedstock for the C&S ( Cracking and Separation) plant in Malaysia.

7.The C& S plant in Malaysia is known as Lynas Advanced Materials Plant or LAMP.

8. The LAMP is a chemical plant where the Lanthanide Concentrate will be treated in a chemical process that involves the use of very large quantities of acids and various other chemicals.

9.Briefly ,the Concentrate will be reacted with concentrated Sulphuric Acids in a rotary kiln followed by water leaching of the calcine and several subsequent stages of leaching, purification and solid liquid separation. Solvent extraction will be used to separate, purify and concentrate the lanthanide elements to produce a range of carbonate and oxide products.

10.Cracking of the lanthanide concentrate involves a process of treatment by concentrated sulphuric acid and thermal treatment just below its melting point. The process is known as 'Calcine or Calcination'. This process drives 99% of the Thorium content in the ore into the solid WLP residue.

11.33,000 tonnes of concentrate will be processed in each of the first two years of operation and subsequently 65,000 tonnes (dry mass). It is anticipated that in the each of the first two years of operation 11,000 tonnes of separated rare earth oxides will be produced and double that amount in subsequent years.



- Once the cracking is completed in the rotary kiln, the slurry of lanthanide-acid mixture goes through a 3 stage leaching process with clean water;

- After the primary leach the slurry will be filtered in 2 filter presses to enable solid-liquid separation;

- The primary filter cake is transferred to the second stage leaching and filtration. Filtrate from this stage will be recycled to the primary leach circuit and filter cake will be mixed with water for the third stage leaching.;

- The final solid residue from this leaching process is the Water Leached Purification (WLP) residues. They will be stored on site in the WLP storage cells (RSF).

Next comes the Extraction .....

- Extraction of various lanthanide compounds ( Rare Earth Elements) is accomplished with various solvents in 6 separate long solvent extraction (SX) circuits (trains) as shown below:
- SX1- SEG and HRE extraction;
- SX2- LCPN extraction;
-SX3- Iron removal
-SX5 -Didymium extraction
-SX6- Cerium extraction
-SX7-Didymium Purification.

- The water and extractants used each year will be as follows:
Water ;-1,605,625 tpa
(200,7 t/hr equivalent to 880 gallons per minute)
MgO :-11,605 tpa
P204:- 245 tpa;
N235 :- 8 tpa;
P507 : 83 tpa;
Kerosene :- 374 tpa
NaOH :- 32,585;
HCL : 65,747 tpa
Na2S :- 82 tpa;
Na2SO4 :- 47 tpa
BaCl2 301 tpa;
Oxalic Acid 4,400 tpa
Lime :- 1.190 tpa

- Most of these reagents (chemicals) are strangers to us but one thing is for sure they are used in such large quantities that all of the resultant byproducts will end up in our environment.

- With this 'heavy price' on our environmental , LAMP will produce the following REOs for sale in the international market : :
- SEG/HRE Carbonate 1,160 tpa
- LCPN Carbonate 5,400 tpa
- Lantunum Chloride, Carbonate, Oxide 2,800 tpa
- Lanthanum- Cerium Carbonate 8.200 tpa
- Cerium Chloride, Carbonate or Oxide 5,400 tpa
- Dydimium Oxide 5,600 tpa
- Neodymium Oxide 2,000 tpa
- Praseodymium Oxides 800 tpa

Total tpa REO 22,500

Post solvent extraction....

- The product solutions from the extraction plant will be channeled to a number of precipitation plants where the solutions will be neutalized, purified before precipitation as carbonate or for didymium an oxalate. The didymium will then be calcined at a temperature of 1000 degrees C to an oxalate.

- All post extraction processes include a hot water wash in its final stage. Thus the effluent discharged into our water pathway has a temperature higher than the ambient temperature!

- This concludes the processes that transformed Lathanide Concentrate into REO.

- Next we will take a look at the wastes produced and the proposed management by the party concerned.

Here are some of the definition of the abbreviations used in the last posting regarding the solvent extractions:

SX1 :-SEG and HRE extraction- Samarium, Europium, Gandolimium, Heavy Rare Earths ;

SX2- LCPN extraction - Lanthanum, Praseodymium, Cerium, Neodymium

All of the above are the various rare earths extracted in LAMP.