Nuclear energy is not the only technology that produces radioactive waste. The proposed Lynas rare earth mining project will produce it as well. Unlike nuclear energy production which has accumulated 50 plus years of rad waste and still no solution- Lynas is being asked to have a solution before they create the problem. Sensible, and essential, as this is it is, of course, being met with fierce resistance from the company. Despite all we've learned of the environmental and human health dangers of radioactive waste, Lynas still wants to pollute first and look for solutions later. Sound familiar? And look where that philosophy has gotten us!

Soo Jin Hou & Muhammad Syawalfiza bin Lokman l Stop Lynas Coalition 16 January, 2012

Lynas has imposed severe restrictions on the viewing of its Radioactive Waste Management Plan (RWMP).  This document is part of the application for the temporary (or pre-operational) license for the Lynas Advanced Materials Plant (LAMP). 

Having briefly read through it, it is easy to see why Lynas has tried to restrict the circulation of this critical document.  It is because the 700,000 people whose lives will be affected by LAMP will be greatly dissatisfied with Lynas' plans.  When the project was first approved, Lynas had planned to commence operation first while finding commercial and disposal solutions for the wastes.  Although these solutions are now presented in much greater detail in the RWMP, the crux of the controversy - the permanent waste disposal plan, has not been satisfactorily answered.

In essence, there are 3 primary solid waste streams from the LAMP, the Neutralization Underflow (NUF), the Flue Gas Desulfurization (FGD) and the Water Leach Purification (WLP) residues.  The first two are classified as non-radioactive and Lynas intends to recycle them as synthetic gypsum for plaster board and cement manufacturing, or as fertilizer.  The last is radioactive and in the likelihood that it cannot be commercialized, it will have to be disposed of in a Permanent Disposal Facility (PDF).

Problem is, just as it was back then, to where?

Lynas has asked to be allowed 14 years to identify the site of the PDF after they have commenced operation.  This is unacceptable to me as a resident of Kuantan.

Locating a radioactive waste repository has always been politically charged.  For example, in the US, the proposal to build a repository in a desert as remote and dry as the Yucca Mountain was met with fierce public opposition.  In all instances where public opposition derails waste relocation plans, the temporary storage becomes the final resting place.

Kicking the can down the road in identifying the PDF site is unacceptable.  The people of greater Kuantan should not be made to live with this uncertainty, especially when the direct benefits are so marginal.

Lynas has classified the WLP waste as Very Low Level Waste (VLLW) using the IAEA standard, instead of the more stringent Low Level Waste (LLW) according to UK's standard [1].  This means that near surface landfill type facility will be used for the PDF instead of more robust containment methods, for example, concrete cells.

By using the less stringent IAEA standard, Lynas has completely disregarded mounting scientific evidences that point to IAEA's underestimation of health risks from internal emitters [2].  Yet, as if IAEA's standards are so sacrosanct, Lynas conveniently neglected IAEA's low rainfall criteria in the selection of the PDF site [3].  Of course, who would expect to find a dry patch of land in tropical Malaysia?

To mitigate the risk of high rainfall, Lynas intends to install a leachate collection system at the bottom of the PDF.  Should rainwater penetrate the residue cover, it will eventually be collected as leachate.  The leachate, which is contaminated with radioactivity, will need to be treated before the water can be disposed of.  Ominously, one of the treatment options is to feed it back to the cracking and separation process of the LAMP, suggesting that the PDF may not be located very far off from Kuantan after all.

We ask that the government honor its promise to put public safety as its highest priority [4].  If Lynas insists to stay in Malaysia, compel them to:

a) Identify the PDF location and do not allow the WLP to be stored on-site at the LAMP.  The waste must be carted away as soon as they are produced.

b) Uphold the precautionary principle by anticipating greater risks than what Lynas is ready to admit.  Reclassify Lynas' waste from VLLW to LLW and engineer a more robust solution than the current landfill type proposal. 

Soo Jin Hou & Muhammad Syawalfiza bin Lokman, Stop Lynas Coalition

References:

[1]  DEFRA, "Policy for the Long Term Management of Solid Low Level Radioactive Waste in the United Kingdom", 26 March 2007.

[2] ECRR, "2010 Recommendations of the European Committee on Radiation Risk", 2010.

[3] IAEA, "Near Surface Disposal of Radioactive Waste", No. WS-R-1, 1999.

[4] Minister of International Trade & Industry, Dato' Sri Mustapa Mohamed and the Minister of Science, Technology and Innovation, Datuk Dr. Maximus Johnity Ongkili, Joint Media Statement on the Report of the IAEA Review Mission on the Radiation Safety Aspects of the Lynas Project,Pahang, 30 June 2011.