Letter to Re - Visit to Singapore High Commission Over the Lynas Advanced Materials Plant (LAMP) - 3 March 2012

8/2/2019 Letter to Re - Visit to Singapore High Commission Over the Lynas Advanced Materials Plant (LAMP) - 3 March 2012

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H.E. ONG KENG YONG

High Commissioner,

High Commission of the Republic of Singapore

Level 15, West Wing

The Icon, No.1, Jalan 1/68F

Jalan Tun Razak50400 Kuala Lumpur

Malaysia

Re: Visit to Singapore High Commission over the Lynas Advanced

Materials Plant (LAMP)

With regards to above matter, we, a group of concerned residents from Kuantan, appreciate the

opportunity given to us to bring to your attention the potential health and environmental risk of theLynas Advanced Materials Plant (LAMP) in Gebeng, Kuantan to the surrounding areas including

neighbouring ASEAN countries.

For the sake of brevity, we shall summarize the potential effects on Singapore in this text, and some

of the justification of our assessment in the appendix.

Background

The Lynas Advanced Materials Plant (known as LAMP herein) will commence its operation to

process enriched rare earth ore (known as concentrates herein) and yield high purity rare earth

oxides. The rare earth mineral will be mined at Mount Weld, Western Australia and subsequently

enriched onsite prior to trucking to Port of Fremantle, 1000 km away. The concentrates will be

loaded into the 20-feet containers and commenced a 4000 km sea voyage to Singapore, where c.a.

4000 containers/year will be unloaded to smaller vessels prior to heading to the Port of Kuantan.

The intended load to LAMP is approximately 65,000 tonnes/year (dry base); 80,000 tonnes/year

(wet base). The rare earth oxides are inherently harmless, however, two elements bound with the

rare earth to form the ore, are radioactive, i.e. thorium and uranium.

Waste Generation Scenario

The LAMP processes require substantial amount of chemicals and reagents, such as sulphuric acid,

magnesium oxide, hydrochloric acid and utilities such as raw water and natural gas. These are

required to extract the rare earth oxides and to generate copious amount of wastes including threetypes of gypsum, i.e. Flue Gas Desulphurisation (FGD), Water Leach Purification (WLP) and

Neutralization Underflow (NUF) residues, flue gas and waste water. In other words, operations

cannot start and continue without the creation of waste.

It is the intention of Lynas to purge almost all radioactive materials (thorium and uranium) and to

channel them to a sole waste stream, known as WLP. The radioactivity concentration in the other 4

waste streams is regarded as either non-detectable or negligible. The table next page summarizes

the characteristics of each waste stream:


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Waste stream Amount Radioactivity Disposal method

Waste water 500 tonnes/hour Negligible Discharged into Balok River, which leads

to the South China Sea

Flue gas 99,344 Nm3/hour Negligible Discharged through smoke stack into

the atmosphere

NUF residue 177,820 tons/year Total activity0.52 Bq/g

Commercialized as fertilizers

FGD residue 58,920 tons/year Total activity

0.47 Bq/g

Commercialized as gypsum board

WLP residue 64,000 tons/year Total activity

62.3 Bq/g

Commercialized as road building

material, failing which it will need to be

permanently isolated

The commercialization of the wastes is still in the R&D stage. There is no indication that there are

any interested buyers for these recycled products. Even if there is, there are serious implications of

such disposal methods, as products containing trace amounts of radioactive elements will be sold

throughout Malaysia, and possibly Singapore.

Lynas intends to commence operation while figuring out what to do with the waste. In the

meantime, they will store the solid residues on-site in open storage ponds, as they have not yet

identified the Permanent Disposal Facility (PDF) where the radioactive wastes are to be buried.

We are very concerned that LAMP poses real risk of contamination because:

1) the site of the plant is on a reclaimed swamp land, and the underground water table is merely

0.95 - 3.5 m below surface.

2) the low-lying area is prone to flooding due to the monsoon rain.

3) the New York Times reported serious construction and design flaws that "have the potential to

cause the plants critical failure in operation" [1,2].4) the half-life of the primary source of radioactivity, i.e. thorium-232 is 14 billion years. This may

result in the accumulation of radioactivity over time from "negligible" sources

We feel, therefore, that the LAMP will bring serious repercussions to the people of Malaysia and

Singapore. It may affect Singapore via these scenarios:

a) Food security

Kuantan is a major seafood producer with 390 registered deep sea trawlers. Significant seafood

caught in Kuantan ends up in Singapore. Radiation risk may spread across border through

radioactivity accumulated in the food chain.

b) Other sources of contamination

Other pathways may come from products that are made with contaminated materials, for example,

palm oil, birds nest, fruits and vegetables, as well as Lynas' proposed products that are made with

their wastes. The US found out the consequences of using gypsum board made with FGD-type

residue, and had in 1989 banned the use of this product. Also, the US EPA also noted that the use of

fertilizers made with NUF-type residue can increase the radioactivity of the produce [3]. Lynas must

not be allowed to spread their pollution.


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c) Risk from transporting the raw material through Singapore

According to the RIA, 65,000 tons per annum will go through Singapore in 4000 containers annually.

Lynas has disclosed that the payload will be sealed inside double layered plastic bags. It will be

transported as non-radioactive but as soon as it touches down in Kuantan, it is classified as

radioactive. This is due to a legal loophole in Australia's Dangerous Goods Act. The construction ofthe bags are not known. We do not know how robust they are. A spill may be disastrous to the

environment.

d) Deterrent to Malaysia's nuclear ambition

Due to its size, Singapore will probably not pursue nuclear power due to these power plants

becoming strategic targets in times of war. This leads to Singapore being unfairly subjected to

radiation risk from its neighbors' nuclear ambitions. If Lynas is allowed to proceed, and the

Malaysian public buy the "radiation safety" propaganda, nuclear plants will be next in line. If we

stop Lynas now, the government will not dare to proceed to nuclear plants due to the political risks.

Malaysia is capable of harnessing renewable energies and Malaysia's wet climate is not suitable fornuclear repositories according to IAEA's guideline [4] . The people of Malaysia and Singapore don't

need any more radiation risk and it is in Singapore's interest that the Malaysian public remains

averse to it.

Finally on 1/3/2012, a few days after the 15,000 strong green rally against Lynas, a Singaporean

academia Professorexpressed doubt over the safety of the plant [5]. Given Malaysia's poorrecord in construction reliability, the most memorable one is the collapse of the roof of a newly

constructed stadium in Terengganu, nobody trusts the incompetent Malaysia government to

manage such a high risk venture.

We hope that the Singapore government agrees that the Lynas project is a reckless industrialexperiment, and we hope that your honorable commissioner can do everything within your

diplomatic power to persuade the Malaysian government to abandon this project.

Yours sincerely,

______________________________

Dr Lee Chee Hong (Technical Advisor for Himpunan Hijau 2.0)

Chin Yee Kaing, Clement (Himpunan Hijau 2.0 PR chief)

Lee Chean Chung (Himpunan Hijau 2.0 publicity chief)

Nasrun Amir Abdullah (Himpunan Hijau 2.0 event coordinator)

Soo Jin Hou (Technical Advisor for Himpunan Hijau 2.0)


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[1] "The Fear of a Toxic Rerun", New York Times, by Keith Bradsher, June 29 2011.

[2] "Rare Earth Metal Refinery Nears Approval", New York Times, by Keith Bradsher, Jan 31,2012

[3] "Phosphogypsum and Imported Drywall" from

http://www.nuclearcrimes.org/phosphogypsum.php

[4] IAEA, "Near Surface Disposal of Radioactive Waste", No. WS-R-1, 1999, pg 14.[5] "", 1/3/2012.

Documents

Letter to Re - Visit to Singapore High Commission Over the Lynas Advanced Materials Plant (LAMP) - 3 March 2012