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.

A video by Friends of the Earth on Ban Cyanide and Stop Lynas's campaigns






https://www.youtube.com/watch?v=kyLKx2GgGlU&app=desktop



“From September 21 - 25, 2014, Friends of the Earth International carried out a solidarity mission in the areas of Bukit Koman and Gebeng in the state of Pahang, Malaysia to investigate into the persecution of environmental advocates and defenders for their resistance against 2 mega projects."

SMSL PRESS STATEMENT 

BY SAVE MALAYSIA STOP LYNAS
JULY 30, 2017
LYNAS MUST DISCLOSE ALL FACTS BEFORE “CONDISOIL” IS RELEASED FOR COMMERCIAL USE

Press Statement by Save Malaysia Stop Lynas on recycling of the so-called Lynas Advanced Materials Plant (LAMP) in Balok, Pahang waste residue into an industrial by-product being marketed as soil conditioner under the name “Condisoil”.

We note with interest all announcements by Lynas on their efforts to recycle LAMP residue into a commercial industrial byproduct called Condisoil.

Due to our proximity to the area and our constant research we believe this is an attempt by Lynas to avert their obligation from building a Permanent Disposal Facility (PDF) as recommended by the IAEA Committee in 2011.

This issue is highly technical and requires extensive research on our part and we implore our fellow malaysians and members of the media to take time, understand the technical details and warn the public of the health and environment hazards involved.

In short Lynas Malaysia is attempting to avoid/escape the construction of a PDF by marketing its waste products as soil conditioner and other industrial products by claiming the radiation output of its waste is “intrinsically low”.

They have grossly misinterpreted a report by the International Atomic Energy Agency (IAEA) report in their efforts to escape their obligation and below is a detailed explanation of our claims:
Here are the facts:

1. In 2014, when the TOL needed to be renewed, Lynas in its 4th Quarterly activities report submitted to ASX on 31 July 2014 under the heading ‘Synthetic Mineral Products Program’, ‘Road base material developed from WLP has been certified by the AELB as non-radioactive material and the Company is preparing to seek Malaysian DOE approval for construction of a demonstration and assessment road using this material.’

‘The Company ,it continued, has gained approval from a customer and is preparing to make the first commercial trial export of NUF. Negotiations are ongoing for further commercial shipments. Lynas has also finalized the specifications for three granulated products for use in broad-acre trials.’
Unknown to all, in April 2014 The Malaysian Journal of Analytical Sciences, has published a paper on an attempt by UKM to extract Thorium from WLP in a Digestion Study. The paper was published under the heading ‘ Digestion Study of Water leach Purification (WLP) residue for possibility of Thorium extraction.’ The success rate was merely 5%.

In the paper WLP was found to contain Thorium concentration of 1952.9 mg/kg Uranium 17.2 mg/kg. According to Lynas over 99% of thorium in the feed lanthanide concentrate is removed to WLP and through calcination at temperatures up to 600 degrees C. The Thorium concentration in WLP of 1952.9ppm has a radioactivity of 7.98 Bq/g which was higher than what Lynas officially declared of 6 1 Bq/g, therefore it needs to be considered for regulatory control as the radioactive residue.

In the face of this scientific report, it defies one’s imagination to believe what was ‘dished out’ above by Lynas on claims that AELB certified road base material developed from WLP is non-radioactive!

2. On Dec 18 2016, it was reported by the Sundaily.com that the Vice president of Lynas Malaysia, Datuk Mashal Ahmad said that UPM and MARDI was running field tests on a soil conditioner that was derived from its WLP residue. Its CEO Ms Amanda Lacaze said LAMP produces 3 solid residues two (NUF & FGD) of which are non radioactive while WLP has ‘very low radioactivity.’

It is true that NUF and FGD residues have concentrations of U< 0.0062 Bq/g and Th < 0.002 Bq/g , falling below the threshold of 1 Bq/g thus are non radioactive. They were officially discharged from regulatory control by AELB on 17th Oct 2013 but are still controlled as ‘scheduled waste’ in terms of environmental regulation. Thus they fall under the purview of DOE.
In our interactions with officers from DOE we were made to understand that Condisoil was made from FGD and NUF and it does not contain WLP residue as it is still under regulatory control by AELB.

On 27 July 2017 Lynas released a statement on Condisoil and no details on its composition or formulations were provided except the frequencies these different samples were submitted to SIRIM.
This statement only appeared after the Minister of MOSTI remarked that he agreed with the MP of Kuantan that ‘Lynas has jumped the gun’ as Condisoil is still in the research process. Further in his reply he revealed that the composition of the Condisoil is made up of 1 part WLP; 2 parts NUF and 7 parts FGD in the ratio of 1:2:7! The results of the safety confirmation test will only be known at the end of August.

The question that ought to be pertinently asked is why all these differing contradictory statements from the parties involved? Any discerning individual will conclude that the real issue behind is the insoluble problem of finding a suitable site for PDF and have it constructed according to international practice.

There are many other examples on how Lynas tried to argue that the PDF is not necessary. As an example they ‘quoted ‘ from the IAEA review report that the radiation produced in LAMP is intrinsically low while the review report said the team found that radiation exposure to the ‘PUBLIC’ is intrinsically low.’

We have tried in many past occasions to initiate positive engagements with Lynas Malaysia to seek explanations on issues of grave concern to the residents of Kuantan but were met with outright haughty refusal , the latest being an attempt to provide them a platform to explain their plan to recycle the solid wastes.

The IAEA review report recommended that Lynas be encouraged to maintain an ongoing, proactive approach to relations with the fullest possible range of stakeholders, including active opponents of the plant, keeping a low threshold for engagement and ensuring maximum transparency to address continuing widespread misconceptions.’ They have obviously overlooked this.
In the absence of trust and respect for all the stakeholders in Kuantan, Lynas’ attempt to pull a wool over the residents’ eyes on the recycling narrative will one day destine to meet its karma.

Issued by
Save Malaysia Stop Lynas steering Committee
29th July 2017

http://www.thesundaily.my/news/2017/07/25/lynass-condisoil-yet-receive-sirim-green-light

KUALA LUMPUR: Sirim is yet to give the green light for condisoil, a soil conditioner derived from residue produced by the the rare earth plant run by Lynas.

Science, Technology and Innovations Minister Datuk Seri Wilfred Madius Tangau said Sirim has not completed its test on the condisoil.

He said Lynas has jumped the gun in stating that Sirim has given safety confirmation for its condisoil.

"I agree that Lynas has jumped the gun as the test is still underway.

"It is better to leave it to Sirim to complete its work and let the Environment Department announce the results," Wilfred told Fuziah Salleh (PKR-Kuantan) in the Dewan Rakyat today during Question Time.

Fuziah said Lynas had in its email to the Save Malaysia; Stop Lynas chairman stated that "the condisoil is non-toxic, non-radioactive".

"I think this is jumping the gun as you said the test is still underway," she told Madius.

Wilfred said Lynas has appointed Sirim as the condisoil standard certification consultant.

"As of now the safety confirmation test is still being conducted by Sirim. The final report will be released by end of August," he said.

It was reported that Lynas said the Atomic Energy Licensing Board and Nuclear Malaysia has confirmed that the condisoil is non-radioactive and that Sirim has confirmed it to be non-carcinogenic and non-ecotoxic.

Rare earth mining company Lynas Corporation hopes to process residue from its production operations for commercial use next year.

In an interview last year, Lynas Malaysia Sdn Bhd vice-president Datuk Mashal Ahmad had said 211,454 metric tonnes of residue are being stored at its advanced material plant and it is collaborating with two institutions to turn the waste into material for use in agriculture.

He said Universiti Putra Malaysia (UPM) and the Malaysian Agricultural Research and Develop­ment Institute (Mardi) is running field tests on a soil conditioner that was derived from its water leach purification (WLP) residue.

"Researchers from both institutes have tested this conditioner, called "Condisoil", on various crops including corn, kenaf, paddy, coconut and cattle-grass.

"After two harvest seasons, the initial results are amazing, with the growth rate of the plants doubled using Condisoil," he said.

https://www.facebook.com/YBFuziahSalleh/posts/759620364206293:0

UPDATE: Lynas 'condisoil'

Jawapan Menteri jelas membuktikan bahawa CEO Lynas berbohong apabila beliau buat kenyataan bahawa 'condisoil' dari Lynas telah mendapat kelulusan SIRIM

Soalan saya untuk sesi MQT (Minister Question Time) pada hari ini 25/7/2017 adalah di rujuk.

Soalan saya berbunyi :

1) Puan Hajah Fuziah Salleh (Kuantan) Minta MENTERI Sains, Teknologi dan Innovasi (MOSTI) menjelaskan berkenaan kenyataan Lynas pada 19hb July 2017 bahawa mereka telah berjaya mencari kaedah untuk mencipta 'condisoil' daripada residue kilang Lynas yang telah mendapat pengesahan keselamatan dari SIRIM.

CEO Lynas, Amanda Lacaze telah membuat kenyataan bahawa 'condisoil' dari residue Lynas telah mendapat kelulusan SIRIM sewaktu majlis rumah terbuka Hari Raya anjuran Lynas dan kenyataan tersebut telah mendapat liputan media tempatan.

Akan tetapi jawapan Menteri MOSTI tadi menjelaskan bahawa kajian keselamatan oleh SIRIM masih dijalankan dan dijangka berakhir pada penghujung bulan Ogos.

Maka mana mungkin pihak SIRIM telah meluluskan 'condisoil' tersebut, sekiranya kajian keselamatan masih di jalankan. Malah Menteri juga bersetuju bahawa CEO Lynas telah 'jump the gun' dengan kenyataan tersebut.

Justeru itu saya ingin memberi amaran kepada Amanda Lacaze dan Lynas supaya jangan bermain dengan isu yang melibatkan keselamatan rakyat. Kami warga Kuantan bukan bodoh yang boleh dikelabui mata dan di mainkan sewenangnya oleh initiatif perhubungan awam pihak Lynas.

Ada banyak lagi yang Lynas patut buat dari segi keselamatan awam seperti mengenalpasti tapak PDF ( Permanent Disposal Facility) yang sehingga kini masih belum dikenalpasti, walaupun ianya wajib dikenalpasti dalam tempoh 10 bulan TOL (Temporary Operating License) keatas Lynas di keluarkan pada September 2012. Juga syarat yang di kenakan ialah Lynas wajib kenalpasti PDF walaupun ada pelan alternative untuk residue Lynas, seperti kitar semula dan sebagainya.

Jangan ingat apabila Lynas menanam pokok di Kuantan, ianya terus menjadikan Lynas satu industri hijau. Juga jangan ingat apabila Lynas beri sumbangan kepada orang miskin, itu terus menunjukkan Lynas mempunyai sifat bertanggungjawab. Warga Kuantan tidak sebodoh itu untuk terus dipermainkan

Berbohong didalam sidang media ialah satu jenayah Corporate kepada awam. Ianya menunjukkan bahawa syarikat tersebut tidak bertanggungjawab dan tidak boleh dipercayai. Syarikat tersebut ialah Lynas Corporation (M) Sdn Bhd.

Hajah Fuziah Salleh
Ahli Parlimen Kuantan
Parti Keadilan Rakyat
Pakatan Harapan
#BinaSemulaNegara

https://www.facebook.com/YBFuziahSalleh/videos/759476814220648/



MQT- Minister Question Time

Sidang Dewan Rakyat 25 Julai 2017 (sesi pagi)

Soalan saya berbunyi

1) Puan Hajah Fuziah Salleh (Kuantan) Minta MENTERI Sains, Teknologi dan Innovasi (MOSTI) menjelaskan berkenaan kenyataan Lynas pada 19hb July 2017 bahawa mereka telah berjaya mencari kaedah untuk mencipta 'condisoil' daripada residue kilang Lynas yang telah mendapat pengesahan keselamatan dari SIRIM.


Jelas daripada jawapan Menteri bahawa CEO Lynas Amanda Lacaze telah berbohong didalam sidang medianya dimana beliau menbuat kenyataan bahawa 'condisoil' ataupun soil conditioner yang di buat dari sisa kilang Lynas telah mendapat kelulusan SIRIM

Jawapan Menteri menyatakan bahawa kajian keselamatan masih lagi dijalankan.
Mana mungkin dah dpt kelulusan SIRIM sekiranya masih buat kajian

LYNAS LAMP UPDATE FORUM

Sin Chew Newspaper (19/07/2017)




In today's SinChew.

If you can read Chinese, then you will believe that they have successfully turned the radioactive waste WLP into the product called 'Condisoil'!

Is this a Nobel prize winning feat or a mere PR stance to fool the uninformed?

We will explain to you the details of Lynas' recycling of the 'wastes' produced at LAMP this coming Sunday at Pusat Komuniti DUN Semambu.

Make sure you attend so that you can hear both sides of the story and you will know if Lynas needs to build the PDF.

See you at 2 pm at the DUN Semambu Community Centre on 23rd July 2017( Sunday)

http://www.abc.net.au/news/2016-09-08/uranium-discovered-in-moonbi-kootingal-in-northern-nsw/7824920


Uranium discovered in water supply for Moonbi and Kootingal in northern NSW

Elevated levels of uranium have been discovered in groundwater supplies for two small towns in northern New South Wales.

The amount of uranium discovered in the water that goes to Moonbi and Kootingal, both located about 20 kilometres north-east of Tamworth, in July during routine bore water testing, were higher than those outlined in the Australian Drinking Water Guidelines.

The elevated levels were confirmed in August.

Now both towns are being supplied with water from Tamworth.

But independent water expert, Professor Peter Coombes from Swinburne University, has called for calm.

"From a health perspective, a one off, small exceedance of most elements is not a drinking water guideline exceedance, you need continuous exceedance of the guidelines for uranium or any other element," Professor Coombes said.

"We hear these alarming stories for alternative water sources every now and again, but we have to realise water contains a range of elements at quite low levels."

The tests found uranium levels of 0.032 milligrams.

Australian Drinking Water Guidelines list the safe level for human health at 0.017 milligrams, and the World Health Organisation lists the safe level at 0.03 milligrams.

Professor Coombes said there was no point "rushing to alarm until we are sure" and multiple tests were needed to gauge consistency of the levels.

"We've got a number of cases throughout Australia and internationally where the water companies have not told communities of [elevated contamination] levels for a long time," Professor Coombes said.


"Background levels of these elements are natural and are expected so there is no reason for alarm or concern because they are just normal."
Council working to determine impact

Tamworth Regional Council's director of water, Bruce Logan, said he did not know if there had been an impact on residents.

"We're speaking to the Department of Health to try to get their advice on what the implications for the levels have been," Mr Logan said.

"I don't want to speculate at this stage, we'll see what the Department of Health has to say and then we'll let the community know."

It is believed the uranium is from a naturally occurring source.


"Uranium occurs in geology and we understand what's happened is one of the supplies, water has infiltrated through some rocks that contain uranium and that's got into the ground water supply."

"It's not unusual, uranium is naturally occurring but the levels that we're seeing are elevated at the moment."

Mr Logan said under the guidelines testing for uranium was required every six months, and as far as he knew, that testing regime had been adhered to.

He has defended the amount of time it took the council to inform the community about the elevated uranium levels, saying that they wanted to wait until they had more information.

"We felt that trying to get some answers would be a better idea to what the community might ask, rather than going and telling them something and not having the answers to the questions that might ask," Mr Logan said.

"The Department of Health will tell us what they want.

"We've given them information, they may say: 'we need more information', that might include going back and testing some of the bores, the water that's in the bores now, I don't know what they will say.

"But essentially, because we're no longer supplying Moonbi [and] Kootingal there is no risk to anyone out there now."

 https://www.malaysiakini.com/letters/354931?utm_source=dlvr.it&utm_medium=facebook

In response to our press statement on the renewal of the Full Operating Stage Licence for another three years, Lynas now claims there is no need for a Permanent Disposal Facility ( PDF) in view of their field trials and the possibility of commercialisation of their ‘solid residues from Lamp’.

This is a gross misrepresentation of the facts though the term ‘solids from Lamp’ is technically correct.

1. The Lynas Advanced Materials Plant (Lamp) produces three kinds of solid ‘residues’ (Lynas preferred the term residues to that of wastes because they claim that these ‘residues’ can be recycled), the first of which is called FGD (Flue Gas Desulphurisation). This together with the NUF (Neutralization Underflow) ‘residues’ are not classified as scheduled wastes as they are not radioactively potent.

The third category of waste is called WLP (Water leached Purification) ‘residues’ which are radioactive as it has a radioactivity of 6.4 Bq/gm.

It is the last category of ‘residues’ that the IAEA recommended to have them stored in a Permanent Disposal Facility.

2. The broad statement that ‘field trials and commercialidation of their ‘solid residues from Lamp’ does not differentiate between the radioactive one from that of the non scheduled wastes. Even if the field trials and commercialization is viable for the radioactive WLP ‘residues’, the need for a PDF would still be required as the decommissioning of the plant will require it to be identified and built.

3. It is both technically and financially not viable to recycle the radioactive WLP ‘residues’ as has been pointed out by us in our memorandums to both the Atomic Energy Licensing Board (AELB) and the Lynas Operation Monitoring Committee (LOMC) prior to Lynas’ first Temporary Operating Licence (TOL) renewal in 2014.

The simple reason being to turn the WLP ‘residues’ into commercial byproducts with less than 1 Bq/gm (so as to be classified as ‘non radioactive’), the costs are too prohibitive. Many other industries had abandoned the idea of recycling their industrial wastes even though theirs are non-scheduled wastes.

4. Lynas is not in any financial position to start recycling any of their ‘solid residues’ now or in the near ‘future’ as can been seen from their yearly financial report. The FY 2016 report is currently overdue.

5. Lynas claimed that currently it has produced 93,300 tonnes of WLP ‘residues’ on dry weight basis. To use this quantity of WLP ‘residues’ before they can be ‘recycled’ into ‘non-radioactive products, it would require a six-fold volume of whatever substance that could be used to dilute it before they can become the feedstock for the industrial product.

‘Preliminary costs practically make recycling impossible’

6. The preliminary costs of drying the WLP pastes before dilution practically make the recycling impossible. All claims on the reuse and recycling of WLP ‘residues’ were put up merely for the sole purpose of acquiring renewals for their Temporary Operating Licence.

7. The need to identify and build a PDF is recommended by IAEA in their 2011 report. Even in their second report (2015) it did not rescind the call to dispense with the PDF. It merely expressed its opinion that the ‘radioactivity’ of the WLP residues was ‘intrinsically low’. (That was after it took them a full month’s delay to ‘describe’ the radioactivity of WLP as ‘intrinsically low’).

8. They have also disclosed that they have submitted a siting plan and an engineering plan for the PDF ‘in accordance to the regulatory requirements’.

This statement underscored the remark made by the former director-general of AELB in 2014 that Lynas had only submitted a ‘conceptual plan of the PDF’ and he further commented that it was not acceptable.

Press statement by Save Malaysia Stop Lynas group on the renewal of LAMP’s FOSL(TOL) on the 2nd September 2016

We note with deep regret and disappointment on AELB’s decision to renew LAMP’s Full Operating Stage License for another 3 years despite our call to its Board to examine the non fulfilment of terms and written undertakings by Lynas with commitments to recycle the radioactive WLP waste into industrial by-products and ship them overseas.

In Lynas Corporation’s announcement made to Australian Stocks Exchange today , it claimed that LAMP’s operations for the past 4 years at Gebeng, Kuantan did not cause notable increases in the background radiation level within 1,5 ,10 and 20 km radius of the plant. It also said the real time readings on the radiation level in the surrounding areas were also made available to AELB and the public online.

This is regrettably assumed by the parties concerned that the communities here are merely concerned with the issue of radiation.
If AELB Board has agreed to renew LAMP’s operating license for another 3 years based on this point of submission, we wish to remind all members of the Board that all the commitments and written undertakings by Lynas in regards to the management of the radioactive WLP wastes and identifying a location for the Permanent Deposit Facility (PDF) have yet to be fulfilled!

Since the first issuance of the Temporary Operating license in 2012, AELB has never made any announcements nor responded to public requests on the data of wastes they promised to collect in order to check if these data tally with that submitted by Lynas in their TOL application documents. This is important because Lynas did not build any pilot plant prior to setting up LAMP and all data on wastes were based on hypothetical calculations.

Neither has the other regulating authority like DOE.

This is in stark contrast to their statement that the ‘renewal followed a rigorous review undertaken by the AELB and other independent regulatory bodies in Malaysia.’

We wish to state here that our regulatory bodies concerned have yet to state openly, publish or respond to public’s criticisms on the matters mentioned above. This demonstrated clearly that they have ‘hidden’ themselves behind the stone wall of silence and are not ready to make themselves accountable for decisions they had made!

In our Memo to the Board on the 25th August, we reminded all members of the AELB Board that should it accede to the agreement to renew LAMP’s FOSL (TOL), they should be mindful of the ‘legacy’ they will be remembered by by the future generations of Malaysians for allowing profits to take precedent over people’s well beings.

With the approval of the Board to renew LAMP’s FOSL till September 2019, it testified to the fact that the Board has scant regards for the toxic legacy that their decision will help leave behind for our future generations!

Dated 2nd September 2016

http://www.malaysiakini.com/news/354571

Press statement by Save Malaysia Stop Lynas (SMSL) on the coming renewal of Temporary Operating License before 3rd September 2016 to Lynas Advanced Materials Plant(LAMP) at Gebeng, Pahang.

Lynas Advanced Materials Plant (LAMP) has been operating with a Temporary Operating License (TOL) since 3rd September 2012. The TOL was renewed under the name of Full Operating Stage License in September 2014. It is due for another round of renewal in September 2016.

We hereby strongly urge AELB and the Committee that sits and deliberates over LAMP’s application for renewal of TOL to consider the following reasons before deciding to grant them a renewal:

1. In 2012, before issuing Lynas the first TOL, the Director General of AELB, Dato Raja Abdul Aziz said they needed to let it run to collect the waste samples for analysis and compare with the data provided in their documents accompanying their application for TOL.

Till this date AELB has not declared or stated openly if the analysis done on samples of wastes collected tallied or complied with the projected figures as provided by Lynas.

2. Prior to issuing the TOL, Lynas had given a written undertaking to AELB and the Malaysian Government to dispose of the radioactive WLP wastes generated either by recycling it into industrial byproducts or ship them overseas. It is based on this undertaking that the TOL was granted and issued by AELB.

In the ensuing months and just prior to its first renewal (which they renamed the TOL as FOSL) they claimed to have carried out research and were ready to pave a road using this byproduct called road aggregates. Nothing further was heard about this soon after the TOL was renewed!

3. The panel of experts from IAEA has recommended a permanent disposal facility (PDF)be identified for the proper disposal of the WLP waste and the decommissioning before an operating license is issued. This was not adhered to both by Lynas and AELB.

Ironically, Lynas submitted a conceptual plan for the proposed PDF and based on that AELB issued the TOL!

This is a gross dereliction of duty by AELB as the regulating authorities!

4. Lynas is presently unlikely to fulfill any of the promises they had given or pledged because of its dire financial position. They would have defaulted on their debt repayment since last year if their creditors had not agreed to a restructuring of the repayments! They even requested for permission from their creditors to allow them to draw down on the interests paid to them to be used as operating capital as reported in their announcement to the ASX recently.

Given the critical financial position Lynas is in, we wish to know if the safe deposits due to AELB each year have been accordingly paid in full as stated in the schedule?

This is important as the safe deposit shall be used to manage the wastes left behind should Lynas cease operating due to whatever reasons.

5. From the data given by Lynas in its RWMP, for each Kilogram of REE refined from REO, there will be 13.365 kg of solid waste produced inclusive of 2.84 kg of radioactive WLP waste by LAMP.

Ending 30th June 2016, LAMP has produced a total of 28,270 tons of REE.

The total waste breakdown of each category of solid wastes is as below:

NUF : 223,395.82 tons

FGD : 74,029.70 tons

WLP : 80,412.44 tons

Solid waste in retention ponds: 1,256.44 tons.

The total solid waste produced to date adds up to a grand total of more than 379,094.40 tons!

LAMP is in full operation since the month of June this year. This means it is producing more and more solid wastes each day.

Lynas has in 2014, declared that it had found a way to recycle the WLP into road aggregates and was waiting to pave an experimental road for long term observation and monitoring. That was announced before it acquired its renewal of the TOL.

This time, through our esteemed MITI Minister’s mouth, we were told that Lynas has done research to turn WLP into soil enhancer and it is waiting to carry out the field tests sometime next year! Again this is announced prior to the renewal of TOL due this September!

Are these announcements coincidental or cleverly contrived to pressure AELB into granting them the TOL renewals?

Given the financial difficulties Lynas is now facing, it cannot possibly allocate any funds to structure a concrete plan to manage these solid wastes effectively especially the radioactive WLP wastes. Therefore countless future generations of Malaysians will be burdened with this toxic legacy should it cease operation!

Are the AELB Licensing Committee members ready to be remembered as the people solely responsible for this national calamity brought upon by a foreign corporation that used our environment as their toxic radioactive waste dumping ground while reaping profits from its processing operations?

We hereby call upon the Pengarah of AELB to withhold the renewal of its operating license.



Dated 31st July 2016.

https://www.facebook.com/bunteet52/posts/1149030575157356

24th May 2016 marked the end of our long legal tussle with Lynas. The Appeal Court in Putrajaya dismissed with costs Lynas' appeal on a point of law whether the High Court Registrar has the legal authority to determine the quantum of taxation.

The taxation issue arose out of the defamation suit being dropped by Lynas against SMSL, me and 4 others in 2013. Since then our legal counsels had been busy sorting out documents and items on which we can claim expenses in regards to the case.

Before this Lynas offered to compensate us with RM3,000.00 for all the troubles they caused in instituting the defamation suit!

Though we spent hundred of thousands in getting experts from both local and overseas institutions in preparation of our defence, the court ruled that not all were admissible. In the end we were awarded a total of RM 80,505.10 for all claims inclusive of preparation of legal documents.

There is a lesson to be learnt here: Corporations will resort to any means money can employ to harass any party that raised a legitimate protest against their clandestine activities that might have a serious negative impact on the environment.

As can be seen, an e-portal which was sued together with us had no financial means to defend itself had decided to comply with Lynas' demand for an open apology.

We stood firm and were ready to wade through the challenges to prove ourselves. This had the effect of rattling them in their consideration of the possible negative perception of their corporation image internationally ! Thus the defamation suit was dropped!

Sometimes one has to stand firm to allow truth to prevail and this is one incident where we did!

Quick Update On Lynas:

Lynas owes Jogmec/Soljitz US$205 million. They are referred to as the senior creditors and interest rate payable is 6.5% p.a

It technically also owes US$225 million as bonds held by Mt. Kellet with annual interest of 2.75%

On their last submission to ASX, Lynas informed their shareholders that:-

1. All interests due to the creditors from May to Sept 2016 are postponed to Dec 2016
2. The US$2 million payable on 30 June 2016 to Soljitz will be paid thru special redrawing rights agreed upon by both Lynas and their creditors from the restricted JARE account. (What it means is that the US$2 million will be taken from the pool of interests paid by Lynas to both the creditors.
3. The JARE restricted account has a balance of US$1.37 million. Lynas needs the sum and has acquired permission from the creditors to allow them to withdraw it completely. It shall be paid back by Lynas in Dec 2016.

There will be no penalty or interests charged for these arrangements. Therefore, please judge for yourself the chances of Lynas' continued survival in operating the RE business.

Save Malaysia! Stop Lynas!

Press Statement by SMSL on 20th November 2015

On the 16th November 2015, The Star newspaper reported that Lynas Corp Ltd’s Chief Executive Officer (CEO)Amanda Lacaze said;

“It’s hard to run a scare campaign in the face of hard evidence, referring to protests against the plant’s location in Kuantan.”

The ‘hard evidence’ referred to was the claim that the data on “low background radiation and harmful emissions collected by third parties over the last four years…”

It is understandable why she made such a claim at this time of the year. The Annual General Meeting (AGM) of Lynas’ shareholders is to be held on the 23rd November 2015(Monday) in Sydney. We wonder why the regulating authorities, the AELB, had remained absolute silence over the matter and allow an interested party to make such a claim. Isn’t AELB the rightful authorities entrusted to adjudicate on the matter?

The paper further reported that “Lynas Corp’s radiological safety adviser Prof Dr. Ismail Bahari said the company had invested RM50millions into equipment to neutralize any acidity, metals or contaminants from its residue.’’

‘’He further added that another RM75millions was spent on a system to treat its gas emissions and scrub harmful sulfuric acid in the gas”

Should the Kuantan residents feel grateful for the ‘extra mile’ Lynas Malaysia has taken to ensure the emissions are controlled within the permissible limits? If the monies concerned had not been spent how would the stakeholders ever know if LAMP is operating with safe limits of all the harmful substances and gases it produced?

When LAMP was granted the TOL, the DG of AELB Datuk Raja Abdul Aziz Raja Adnan, in reply to questions, said that the TOL was issued with the aim of collecting various DATA to ascertain that LAMP’s gaseous and liquid emissions and solid wastes produced are in accordance to that advanced by Lynas in their documents submitted in support of the application for the operating license. And here we have instead the interested party making all the statements concerning the various data which fall under the duties and role of the regulating authorities to collect and verify.

We hereby urge the Atomic Energy Licensing Board to come forward to state and verify if Lynas Corp’s claims on emissions and wastes are authentically accurate.

https://m.malaysiakini.com/letters/320397