LAMP -- RIA, IAEA Where do things stand now?

Prepared by DR. LEE CHEE HONG

Outlines
Quick recap of the rare earth process and the radiation risks RIA report IAEA peer review report Regulations and standards Summary

 Most rare earth elements are harmless, however the rare earth ore (monazite) from which the REE are extracted, is bound with the radioactive substances in it. Radioactive substances in question are Thorium and Uranium

Mt. Weld Concentration Plant To produce ore contains primarily monazite, with c.a. 40% rare earth trucked to concentration plant, 1.5 km away Mount Weld Mine Western Australia - Mine contains average 9% Rare Earth, soil, organic matter, rocks, sand, various minerals and 0.04% thorium + uranium Concentrates will be trucked 1000 km to Port of Fremantle

LAMP, Gebeng, Kuantan FEED : - Concentrates at 40% REO and contain 0.17% Thorium & uranium

> 4000 km voyage from Port of Fremantle to Kuantan (via Singapore), approx 65,000 tonnes per year of concentrates will be delivered.

Wastes produced - Waste water - Waste gas - Three types of Gypsum (FGD, WLP, NUF)

Finished Products: Refined rare earth up to 99.9999% 11,000 tonnes in the 1st year; 22,000 tonnes/yr subsequently
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Rare Earth Oxide Lanthanum Oxide Cerium Oxide Neodymium Oxide Praseodymium Oxide Samarium Oxide Dysprosium Oxide Europium Oxide Terbium Oxide Mt Weld basket price

Mt Weld Distribution 25.50% 46.74% 18.50% 5.32% 2.27% 0.124% 0.443% 0.068%

2008 $8.71 $4.56 $31.90 $29.48 $5.20 $118.49 $481.92 $720.77 $14.87

2009 $4.88 $3.88 $19.12 $18.03 $3.40 $115.67 $492.92 $361.67 $10.32

Q4 2010 $52.49 $52.62 $81.38 $78.62 $36.58 $287.85 $611.54 $620.38 $62.18

Q1 2011 20/06/11 18/07/11 $75.87 $77.52 $130.23 $119.65 $72.75 $140.10 $150.60 $330.00 $235.50 $135.60 $153.00 $159.00 $320.00 $250.00 $130.00

$412.90 $1,470.00 $2850.00 $719.20 $3,400.00 $5880.00 $717.60 $2,800.00 $4520.00 $92.84 $203.69 $223.78

* Lynas official websites

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Radioactive materials

Radioactive decay products

Radiation (alpha, beta and trace of gamma)

External

Internal

Radioactive materials unstable naturally Decay (change) into different elements Radon gas, is a colorless, odorless, toxic gases that is heavier than air. It can damage cells and cause cancer* Lead, a neurotoxin that can harm the nerve system and cause brain and blood diseases*

* when these get into human body

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Radioactive materials

Few meters to few tens of meter

Alpha Ray. Travel distance < 10 cm Beta Ray. Travel distance < 100 meter
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Radiological Impact Assessment (RIA)

To assess potential radiological impact caused by operation of the plant. Prepared by Nuklear Malaysia, Lynas remains responsible for it and its results Based upon information provided by Lynas. (Sect 6.1) Not cover non-radiological safety aspects. Not cover decommissioning nor disposal of the plant The format of reporting is based upon AELB guideline, LEM/TEK/30, which was written for Oil & Gas industry. (p4, para3) Approved onsite disposal of WLP waste but did not assess long term waste storage; nor assess the waste (water/gas) treatment system.
continue
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Feedstock scenario
Lynas claimed Concentrated ore (Feedstock to LAMP) contained : 0.16% Thorium oxide 0.0029% Uranium oxide

WLP waste : 0.1655% Thorium oxide 0.00225% Uranium oxide

Other : neg. % Thorium oxide neg. % Uranium oxide

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Feedstock scenario

P.M.B. PILLAI, Naturally occurring radioactive material (NORM) in the extraction and processing of rare earths, Naturally Occurring Radioactive Materials (NORM IV), IAEA, Seville (2007), 197 221
* Dr. Pillai is one of members that of the IAEA review panel; and the only Rare earth process expert in the team.
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Wastes scenario
neg Thorium & Uranium Waste gas neg Thorium & Uranium Atmosphere, water streams FGD 12 ppm Thorium 0.3 ppm Uranium FEED 1600 ppm Thorium 29 ppm Uranium WLP 1655 ppm Thorium 22.5 ppm Uranium NUF c.a. 6 ppm Thorium neg ppm Uranium Process Waste water neg Thorium & Uranium Recycled, reused? Atmosphere

Stored onsite

Recycled, reused? Sg. Balok -> Sea

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 Fail to specified regular discharge limits of radioactive materials into waste streams. (p26, para4) AELB to decide Probability of radioactive leakage to the waste water and gas is regarded ZERO. (p49); radiation exposure in the process regarded same as the natural background level didnt envisage process upsets, equipment failures. Flying dusts ONLY dispersed during loading/unloading and internal emitter / radiation ONLY affect truck drivers and operators. (Sect 6.4); (p45) it was believed by RIA the slightly wetted materials do not give off flying dust at ALL. Worst accident can ever happened in LAMP is truck overturn. (p50, para2) process is fully automated, total plant shutdown Did not consider the release of Radon gas can pose danger (p45, para1; p48, para3) due to in-situ air dilution, dynamic air flow The ONLY public exposure pathway drinking water and ingesting fish from river nearby (p47) disregard airborne dust
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What IAEA says about RIA?

Generally, IAEA in agreement with the RIA report, with the exception:
To revise WLP long term management plan To revise decommissioning and dismantling plan Assessment of the exposure and environmental monitoring results

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IAEA Peer Review

Upon the overwhelming concern from the public May 2011 - Malaysia Govt appointed International Atomic Energy Agency (IAEA) to review the radiation safety aspects of the LAMP Was once regarded as the ultimate assessment that approves this controversial project 10 international experts formed the review panel, primarily from the nuclear and radiation safety background
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IAEA review team

IAEA staff members x 5
3 nuclear physicists, 1 PR officer, 1 admin officer

International experts x 5
2 nuclear safety experts, 1 nuclear physicist, 1 radioactive materials transportation expert, 1 rare earth safety expert

What about expertise in health, environmental, process safety, waste treatment etc??
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Scope of the Review

Radiation safety aspect ONLY (p 1, para 3) Compliance to the standards and regulations (p1) Construction license (Class A (b)) phase only, review upon project documentation available in this phase plus interviews (p1, para 5) Other licensing phases, i.e. siting [Class A (a)], pre-operational [Class A (c) Temporary], operational [Class A (c) Full], and decommissioning [Class G] are not covered (p1, para 5).
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Scope of the Review

To provide recommendations The review only cover (IAEA, p3, para 2):
a) b) c) d) e) Radiation protection Chapter 2 Waste management Chapter 3 Decommissioning and remediation Chapter 4 Transport Chapter 5 Safety assessment Chapter 6

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Scope of the Review

2. Radiation protection Details to refer to RPP, IAEA Safety Guide/Report - external radiation protection only, internal radiation, hazards in process neg. 3. Waste management rephrased FGD/NUF will be recycled, applauded Lynas plan to recycle WLP. Did mention RSF permanent sites. Discharge limits not mentioned AELB to decide 4. Decommissioning and remediation Details to refer Lynas D&D plan; IAEA standards on D&D 5. Transport exempted by Australian and international regulations, except Malaysia, but 6. Safety assessment focused on waste, external radiation. Not internal emitter, flying dust, decay products
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Outcome and findings of the review

A 55 pages report 7 pages of introduction, 31 pages of contents and 17 pages of Appendixes. With 11 recommendations. Review team was not able to identify noncompliances with the International radiation safety standards Identified 10 issues, which to be dealt with 11 recommendations

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11 recommendations
1. Long term waste management after closure 2. Waste management from decommissioning and dismantling 3. Exposure monitoring and environmental monitoring; dose reduction measures. 4. Develop criteria to allow FGD and NUF to be declared nonradioactive 5. Fund to cover long term waste management cost 6. AELB to have sufficient resources to execute the above 7. Revise and update relevant regulations 8. Enhance understanding, transparency and visibility of AELB regulatory activities 9. Intensity public information and involvement 10. Lynas to intensify communication with stakeholders 11. Malaysian Government to ensure the above are executed.
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General comments
In agreement with the RIA report, with merely 3 exceptions (given in recommendation 1, 2, 3) The review assessed external exposure to gamma ray, which is only trivial in the Thorium and Uranium decay chains! Alpha and beta rays were not mentioned (p15 pt(ii)) No specifically emphasize the rare earth refinery process No emphasize on internal emitters/radiation (p10, para2); (Chapter 2); (p33-34)
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General comments
Decay radionuclides concentrations and hazards from the process materials were not mentioned/ assessed this study is expected to be provided in the next licensing phase (p33 para2) Inhalation of radon gas and ingestion of radioactive dust is not expected to be significant (p33 para4) Contamination of the waster water/waste gas by radioactive materials is neglected (p34 para4); The term TENORM (instead of NORM) should have been used throughout.
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IAEAs uncited and unverified claims

Many similar plants producing RE compounds are operating in various parts of the world. (p1 pt(a)) Many other RE processing plants that are more radioactive operated in compliance with the international safety standards (p2 pt(c)) Critical documents referred in report are not appended
Radiation protection program (RPP) Residue storage facility (RSF) detailed design report Lynas Waste Management Plan Decontamination and decommissioning (D&D) plan Emergency planning & preparedness of radiation protection etc
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What has been missed in the review?

Materials handling, contamination of wastes, discharge limits, process control specs, process/ equipment malfunction, accidents/ incidents (e.g. spillage, seepage, and leakage). Radioactive Waste Classification in accordance to IAEA. No. GSG 1.

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Radiological Waste Classifications

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Near surface: Typically from surface down to 30 meter

24/Jul/11

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24/Jul/11

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Low level waste (LLW) storage guide (IAEA. NO. GSG-1)

LLW suitable for near surface disposal with robust containment and isolation. Near surface depository/ disposal facilities is required for LLW wastes, at depths typically from the surface down to 30 m. In many States it is assumed that institutional controls can be relied upon for a period of up to around 300 years. What we will have in Gebeng??
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International Standards & Malaysia Regulations

Regulating radiation safety is a national responsibilities; in Malaysia, i.e. Atomic Energy Licensing Act 1984 (Act 304), the subsidiary Regulations and Guides. Controlled, maintained, executed, supervised by a regulatory body, i.e. AELB IAEA standards are established for adoption by the members of state in formulating their respective regulations
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ACT 304
Primary legislation "radioactive material" means any nuclear fuel, radioactive product or radioactive waste; Section 26 - No person shall dispose of or cause to be disposed any radioactive waste Section 27 - No person shall accumulate or cause to be accumulated any radioactive waste on any premises

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ACT 304
Both (disposal and accumulation of radioactive wastes) are allowed if prior authorization in writing of the appropriate authority is attained Section 28 - If it appears to the appropriate authority that adequate facilities are not available for the safe accumulation, storage or disposal of any radioactive waste, the appropriate authority may direct the licensee to rectify the situation and the licensee shall give effect to such direction.
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The appropriate authority and the Minister!

"appropriate authority means the Board, AELB To authorize disposal, storage and accumulation of radioactive wastes To establish values for the clearance level, at or below which, the source of radiation may be released from the control of the Act Section 69 - The Minister can impose, exempt any person or class of persons from any or all of the provisions of this Act.
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Act 304 : Remarks

General in nature, no specific and details made on construction, handling and operation of RE plants. (RIA, p4, para2) No definition of radioactive materials in terms of activity concentration (RIA, p5, para1) No clear definition of authorization. (IAEA, p9, para3) No regulation of NORM / TENORM activities (IAEA, p10, pt(c))
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Is this review report justified?

Only emphasis on external radiation not internal emitter, not decay radionuclides Radiation safety aspect only how about health, environment, process, equipment, plant integrity? We dont want a review that didnt cover the entire aspects of the RE refinery process We dont want a review that assumes zero radioactive material release to the environment We dont want a report that review only the CONSTRUCTION phase hypothetical, imaginary We dont a review that relies entirely the data/ information provided by Lynas lack of impartiality and autonomy We dont want a plant that is loosely regulated and controlled. We dont want the LLW to be lying in an open space in Gebeng. We dont want to jeopardy our health and environment as a result of the approval of the plant by this report.
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