The Lynas plant in Kuantan is unravelling into a nightmare. The lanthamide concentrates (rare earths) from Australia that Lynas will import into Malaysia contain thorium AND uranium, which suggests the processing in Kuantan will produce massive amount of radioactive wastes.
Further, there appears to be a serious disconnect in the entire review process of the Lynas plant. There seems to be two separate approval processes i.e. the Environmental Impact Assessment (EIA) under the DOE (Department of Environment) within the Ministry of Natural Resources and Environment(MNRE), and the Radiological Impact Assessment (RIA) under the Atomic Energy Licensing Board (AELB) within the MOSTI (Ministry of Science, Technology and Innovation).
Unknown to the public the poorly done Preliminary Environmental Impact Assessment (PEIA) for Lynas does not cover the radiation and health concerns. In fact, the PEIA does not explicitly mention the exclusion of radiation aspects from the scope of the EIA in its Introduction. Instead, the exclusion is specifically mentioned only in the later chapters e.g. in Chapter 8 on 'Summary and Conclusion' (page 8-13).
In addition, the PEIA mentions a Radiological Impact Assessment (RIA) but not in a clear manner. For example, in Chapter 2 of the PEIA, it states that, “The Malaysian Nuclear Agency [MNA], the radiological consultants appointed by Lynas are presently in the midst of determining radiation safety issues pertaining to lanthamide concentrate storage, handling and transport.”
At the end of Chapter 3, the PEIA states for the first time that wastes produced in the plant operations are radioactive and that their storage will be done according to the recommendations based on the MNA's 'Radiological Impact Assessment' carried out for the project (page 3-7).
The Lynas project was fast tracked for approval by the Pahang State DOE, within two or three weeks of submission. The DOE received the PEIA on Jan 21, 2008 and approved it in early February.
For such a complex project involving radiation hazards with a very vague waste management, storage and disposal proposal, the speedy approval raises serious questions.
This is especially when the PEIA was submitted and approved, the RIA on radiation safety issues was still in the process of being written by the MNA for submission to the AELB. In light of this, our concerns are as follows:
Firstly, how could the PEIA recommend the 'build' option (page 3-8) when the radiation safety issues have not been considered? How could the state DOE have approved the PEIA in such haste?
Note that in the PEIA, the waste management proposal is vague and inadequate. They include the following:
- the space for underground wastes storage cells is very limited due to the groundwater being extremely close to the surface;
- the ground is susceptible to subsidence as it is a former peat swamp area;
- the release of dangerous wastes into Sg Balok and subsequently into the sea;
- the dangerous and toxic radioactive wastes which are supposed to be carefully stored onsite in special ponds and storage cells but then schizophrenically proposed to be re-used as fertilisers, concrete, plasterboards, for roads, etc (page 5-58, 59).
Secondly, the fact that there is an RIA independent of the PEIA means that there are now two independent and parallel impact assessments in existence. This is setting a dangerous precedent in the entire review process.
Under Malaysia's environmental laws, the DoE is the primary coordinating authority on issues related to the environment and its impact on the well being of its citizens. The MNA and AELB are promoters of nuclear technology and this may give rise to conflicts of interests as MNA is the consultant that wrote the RIA for Lynas.
Thus, how effective will the DoE be in achieving its mandate to protect the environment and the well being of the people? How independent and autonomous is the DOE from the MNA-AELB?
Will DOE'S policies and decisions be subservient to the interests of the AELB? Will DoE have to relegate its role to the AELB in nuclear matters and issues related to radiation and its impacts? These questions have a crucial bearing on the credibility of the Lynas review process.
Thirdly, what is the RIA assessment and approval procedure under the AELB? While the general EIA process under the DOE is widely published and publicly available (e.g. on the DOE website), in comparison, the RIA process remains completely unknown and uncharted territory.
Which governmental agencies were on the RIA approval panel? What are the criteria for the RIA assessment? Why is the RIA or its contents not available for scrutiny by independent experts?
Fourthly, Lynas is required to apply to the AELB separate licences for siting, construction, importation of radioactive materials, onsite storage of radioactive wastes, temporary operation, and permanent operation. It is unclear if Lynas has all the licences to operate. AELB has said only siting and construction licences were approved.
Fifthly, the poorly done PEIA also lacks a proper socio-economic assessment. No costs-benefits assessment (CBA) was performed. The major reason given in the PEIA for the built option recommendation for the Lynas project is the large financial and economic benefits promised.
The lack of proper socio-economic analyses and CBA invalidates the recommended built option. For example, what are the values assigned for people's health, tourism, fisheries and other industries in the area and what happens when these are affected by the Lynas project?
One should also consider examples of the long-term health impacts of the Asian Rare Earth case in Perak, and the rare earths industry in China.
These are critical issues that need to be addressed concerning the Lynas project. Given the above, CAP and SAM recommend that:
- The Lynas project be stopped in order to address the issues, including the Wastes Management Plan, which an Australian mining expert reported as being 'yet to be disclosed by Lynas';
- A transparent, integrated assessment be done for projects requiring both EIA and RIA. This would prevent a PEIA or DEIA (detailed EIA) being approved while not knowing the full radiological safety impacts in an RIA;
- A DEIA be legally required for any project that requires an RIA, thus ensuring a more thorough review process. This is only logical, considering less hazardous activities require detailed environmental impact assessments. Further, unlike a PEIA, a DEIA makes public participation mandatory;
- Proper socio-economic analyses be a requirement for all EIAs, whether preliminary or detailed;
- Politicians (state and federal) should not make claims that controversial projects are safe as unqualified political endorsements make the project approval process political, very biased and dangerous.
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