Tuesday, December 11, 2012

Lynas (Part II): The Go/No-Go

As of now, whether to continue or to stop the plant operation, Lynas, which is a company from a far away land, will cost Malaysians a fortune. 

Some people may say that Lynas issue is that of a political one and it's mere fear mongering by the Pakatan Rakyat. While there's some element of truth (well, when General Election is near and everything even a hair-cut is politicized, I'll be very insincere to tell you otherwise), I strongly believe the move of anti-Lynas itself is that of a rational one and it is definitely the right thing to do.

This article aims to tell the readers especially those with technical background why we, as rational as we may, should join the effort to stop Lynas. It first gives a background study on Lynas plant operation and then analyze the go and no-go situations. 


Before we proceed further, let's first understand what Lynas Advanced Material Plant (LAMP) is all about. 


Below is a very brief block diagram of LAMP that I drew out according to the process description from Preliminary Report Environmental Impact and Risk Assessment  [1

It's a highly simplified block diagram. I've only shown here the material flows of the concerned streams (potentially radioactive), namely Flue Gas Desulphurisation (FGD), Water Leached Purification (WLP) and Neutralization Under Flow (NUF) residue. The other streams are chemical streams of which chemical industry and regulatory bodies in Malaysia have ample experience in handling and monitoring. 

Safety Concerns

I need to clarify here that LAMP is NOT a nuclear plant, it is a chemical plant. The plant operation and the radioactive waste generated are far less dangerous, therefore the potential accident will be far less severe than that of the nuclear disaster of Chernobyl or recent Fukushima Daiichi. 

However, it is not without concern. Two main safety concerns here are the radioactive exposure during plant operation and the radioactive waste management. 

Safety Concern (I): Plant Operation Exposure

During the plant operation, radioactive exposure can be external or internal. External exposure refers to exposure outside of the body whereas internal exposure refers to exposure inside the body due to ingestion and inhalation. 

The major radioactive components in the waste streams are uranium and thorium, which undergo alpha decay. External exposure of alpha particle is generally not harmful due to its low energy, short travel distance and the fact that it can be stopped by our skin. Therefore, contrary to what some anti-Lynas report say, I support what has been reported by IAEA in saying that the major pathway of external exposure of a worker is gamma ray exposure. It is estimated that the average dosage of  gamma ray exposure of a worker is about 2 mSv per year, 10 times less than international standard [2, p 34]. 

As for internal exposure, ingestion and inhalation of long-lived alpha-emitting radionuclides (uranium and thorium have half-life of 1.4 billion) in air borne dust can be extremely harmful. Alpha particle, if absorbed in the body, is the most harmful type of radiation due to its high energy content. IAEA estimated that if the dust level is controlled and monitored at lower than 0.5 mg/m3 dust level, a worker equivalent dosage due to inhalation is about 0.3 mSv per year with no significant health concern [2, p34].

In short, based on the assumption that the dust level is properly monitored by Lynas and Atomic Energy Licensing Board (AELB), there should be no long-term health impact from either internal or external exposure. In the case of accident, assuming that all potential release points of mass emission of dust can be blocked in time (this should be in LAMP hazard prevention and mitigation plan), there should be no acute radiation resulting from sudden high amounts of radiation exposure.  

Whether or not the said assumptions are reasonable, I leave it for the readers to decide. 

Safety Concern (II): Waste Management

Table below shows the estimated amount of radioactive waste streams, i.e FGD, NUF and WLP from LAMP [2, p16]. When IAEA review team visited Malaysia, Lynas expressed its confidence in processing these radioactive residue streams to non-radioactive by-products with commercial applications as documented in IAEA report on Lynas dated Jun 2011 [2, p17]. In March 2012, Malaysians were assured that if commercial applications are not feasible and no local disposal locations can be found, Lynas will ship the radioactive waste out from the country [3]. We have not heard of anything about recyling the waste to non-radioactive by-products so far but we know now from the Managing Director of LAMP that according to the international convention, the possibility of shipping the radioactive waste out of the country is almost zero [4]. So Malaysians will be faced with radioactive waste management issue if LAMP is going to continue its operation here. 

Table below shows the volume of different waste streams generated according to IAEA report [2p16]

The total volume of waste that will be generated over the next 10 years will be about 2.8 million cubic meter (m3), which is about 1200 Olympic size swimming pool (2500 m3). Due to their low radioactivity, the FGD and NUF streams can be processed to meet the criteria to be treated as non-radioactive [2, p17]. If that's the case, then the volume of radioactive waste will only be that of WLP, which is about 824,000 m3, equivalent to 330 Olympic size swimming pool. 

According to UK standard, WLP waste is low level waste (LLW) and under the regulation it can be stored from surface to 30 m below ground level and the storage of LLW should be for a minimum of 300 years [5, p16]. Assuming a 20 m deep storage pit, for every 10 years of LAMP operation, we'll need an area of 2 football field to be isolated for at least the next 300 hundreds years for LLW storage. 

For comparison purposes, for radioactive waste not disposed of at the mine sites (which is the safest and best practice), Australia has accumulated approximately 4,000 m3 low level and short-lived intermediate level radioactive waste from over 50 years of research, medical and industrial uses of radioactive materials [6, p3]. This is a stark comparison as the Australian company Lynas will now accumulate 824,400 m3 of LLW in Malaysia every 10 years, which is about 200 times of what they accumulated in their own land for 50 years.

Assuming a 20 years operation of Lynas, we'll need an area of 4 football fields to store the waste for the next 300 years. The major concern in the next 300 years of LLW storage is the leakage of radioactive materials to the underground water due to some unforeseen circumstances. This risk can be minimize by rigorous engineering design and stringent monitoring body. However, whether Malaysians want to take this risk, even when it is theoretically minimal, is up to the society to decide. 

My only hope is that the government will fulfill their promise today (10 Dec 2012) of which the Temporary Operating License (TOL) will be suspended if Lynas does not ship the waste abroad [7]. 

The Much Bragged about 'Scientific Evidence' by IAEA Report

Barisan Nasional leaders have time and again reassured us on the 'scientific evidence' in the IAEA report [2claiming that LAMP is safe. However, it's the report that shows how BN and Lynas have fall short of the recommendations made. 

1. The AELB should require Lynas to submit, before the start of operations, a plan 
setting out its intended approach to the long term waste management, in particular management of the water leach purification (WLP) solids after closure of the plant, together with a safety case in support of such a plan.  
Comment: Failed. Lynas started its operation without long term waste management plan.

2. The AELB should require Lynas to submit, before the start of operations, a plan 
for managing the waste from the decommissioning and dismantling of the plant at the end of its life. 
Comment: Failed. Lynas started its operation without proper decommissioning and dismantling plan.

5. The AELB should implement a mechanism for establishing a fund for covering 
the cost of the long term management of waste including decommissioning and remediation. The AELB should require Lynas to make the necessary financial provision. The financial provision should  be regularly monitored and managed in a transparent manner. 
Comment: Only RM50 million has been requested as security deposit [8, p2], compared to the cleaning-up cost of Bukit Merah of RM 300 million[9], not to mention the hundreds of years waste management. 

8. The AELB should enhance the understanding, transparency and visibility of its 
regulatory actions in the eyes of the public, particularly those actions related to inspection and 
enforcement of the proposed rare earths processing facility. 
Comment: Hmmm, apparently the Green Walk has proven that AELB has not done their job well to enhance understanding, transparency and visibility. 

9. The AELB should intensify its activities regarding public information and public involvement. Comment: What? You kidding? Public involvement is never in the their dictionary, they just ignore the public.

11. Based on recommendations 1–10 above, the Government of Malaysia should 
prepare an action plan that: 
(a) Indicates how the above-mentioned recommendations are to be addressed; 
(b) Sets out the corresponding time schedule for the actions; 
(c) Is geared to the possibility of an IAEA-organised follow-up mission, which will review the 
fulfillment of recommendations 1–10 above in, say, one to two years' time, in line with other IAEA 
Comment: So please set-up another follow-up mission by the IAEA team and let them tell you that you have not fulfilled recommendation 1 and 2 - Lynas started its operation before having long-term waste management and plant decommissioning plan. 


Following anti-Lynas movement progress, it is not uncommon to see that they are still people who do not oppose to Lynas because technically, the production of lanthanides can be safe when all the prevention and mitigation measures are complied to and waste management and plant decommission plans are in place. 

However, determining whether a project is safe is not really about whether the project can be theoretically safe, it encompasses the computation of risks that involve many human factors such as the plant data integrity, the rigorousness of the monitoring body etc. For example, a nuclear power plant can be safe on paper technically. Although in the midst of phasing out, France, Germany and UK have been generating electricity with nuclear power plant for nearly 50 years without major accident. In fact, the mortality rate in a nuclear power plant is much smaller than that of coal-fired power plant. However, if you put a nuclear power plant in Malaysia, where regulatory bodies are technically less proficient, less experienced as well as susceptible to corruption and political control, it will only be a disaster in the waiting. 

As I've laid out previously, it involves human factors to ensure the safety of Lynas. The worst case scenario is the internal exposure due to high-level inhalation of air-borne dust resulting from uncontrolled dust level or the ingestion of contaminated ground water resulting from leakages of waste storage. Internal exposure of alpha-emitting radionuclides can be extremely harmful and may cause lives depending on the magnitude of the incidents. 

However, these scenarios are just risks, they may or may not happen.  

Let's now look at Lynas case like any other investment, that is, to see whether the monetary return justifies the risk. The plant construction is RM 2.5 billion. It is also reported that the plant will bring positive multiplier effects to the Malaysian economy (resulting from employment, company and its employees expenditure, utilities, support services such as transport and logistics, banking, insurance etc as well as the tax revenue), Lynas total direct and indirect contributions to the Malaysian economy over the first 15 years is estimated to be RM 6.04 billion [1, p17]. 

For simplicity purpose, let's overestimated that all the capital investment is absorbed by Malaysian economy, i.e to hire local contractors and buy materials locally. Also, let's ignore the fact that the above economic contribution estimation took into account the tax revenue (Lynas actually obtained 12 years of tax exemptions, who knows why). Therefore, at the very maximum, Lynas will bring about  RM 8.54 billion over the next 15 years to Malaysian economy (RM 2.5 billion + RM 6.04 billion) If we extrapolate to 20 years of LAMP operation as expected, it will bring be about RM 10.55 billion to Malaysian economy (RM 2.5 billion + RM 6.04 billion x 20/15). 

Just to put you into perspective, due to inefficiency, about RM 45 billion of PTPTN loan approved can no longer be traced for collection; due to corruption and other illegal practices, the country suffered RM 1 trillion of lost in illicit money. So are we going to take the risk and 300 years of social liability for RM 10.55 billion to Malaysian economy? 

For me, the answer is crystal clear. 


I do not want the readers to be ignorant about what is at stake if we stop Lynas from operating at this point of time - when the contract is signed, the plant is ready and the market is waiting eagerly. 
It is an irreversible situation and will cost us a fortune to reverse the situation, all thanks to the reckless decision by the BN government. 

Firstly, we may have to compensate for the lost of capital and maybe the future earnings depending on the terms and conditions in the contract signed between Lynas and the government. So it may be a compensation of RM 2.5 billion or more. 

Secondly, we'll most likely suffer lost of reputation in the eyes of foreign investors as a breach of contract by the Malaysian government will create credibility issues. This is especially true for Lynas case because the whole rare earth industry is waiting for Lynas and Molycorp production to support the heightened global demand of rare earth elements due to the decreasing supply from China [10, p4]. Lynas was expected to produce about 20,000 metric tons (mt) of the estimated 45,000 to 70,000 mt non-China output needed to support the global demand [10, p4]. This accounts for 25-45% of the non-China output. Therefore stopping Lynas is not only a local issue, it can be potentially a huge news in international business. Whether or not this news will create huge negative impact on our foreign direct investment is yet to know. 


We are now facing with a question of whether we'll sacrifice our short-term gains for long-term benefits. 

If we are looking at long term, I personally think that the "No-Go" situation is less costly the the "Go" situation. This is especially true if Pakatan Rakyat capture Putrajaya in the next general election (sorry, a bit of propaganda here but I am sincere in saying this). When there is a more prudent public finance with less leakages as well as a more competent, accountable and transparent government, we'll earn back (or save) the compensation needed to pay-off Lynas according to the contract. (Of course, I am hoping that we don't need to pay a single cent for that but we'll not know until we see the contract). Through time, we'll also eventually prove to the foreign investors that Malaysia is a good place to invest and Lynas case is just a one-off situation. 

I am not ruling out here the possibility of having rare earth or even nuclear power plant in Malaysia in the future. However, we can only start considering it when the technologies have improved that we'll no longer need to take huge safety risks and long-term social liability, when the government is transparent and accountable to the stakeholders involved, when our regulatory bodies are strong and independent as well as when our civil societies are empowered. 

Until then, for the sake of our children, any projects of this sort should be a no-go. 


That's all for my Go/No-Go analysis. 

I hope that through this article the readers will choose to oppose to Lynas operation in Malaysia not out of emotions and the lack of knowledge as claimed by the BN government but out of rationale and full grasps of the scientific facts behind the issue. 

All in all, let's make Malaysia a better place for our next generation.  


  1. There were far too many questions that only a DETAILED EIA could provide answers to. Those questions should have been asked and demanded.

  2. Good overview of the Lynas project. The author should have included recommendation 6 which implied that the AELB is incompetent and has inadequate capacity nor skills to manage the Lynas project.

  3. Thanks for a far betterstandard of argument than the usual anti-Lynas garbage. I don't agree with your analysis but respect your thoughtful contribution to the debate.
    My points of disagreement:
    - From the table it's clear that the NUF and FGD outputs are non-issues and perfectly capable of useful recycling as plasterboard and fertilizer. That cuts the 'waste' issue down by a factor of 3.
    - The WLP is the critical issue. It is at the lower end of Very Low Level Waste according to the international standards used in Australia and (I believe) Malaysia. As such, if it is to be stored, sufficient is "An adequate level of safety for VLLW may be achieved by its disposal in engineered surface landfill type facilities." In essence, minimal!
    - Mixing the WLP with sand, cement and aggregate WILL dilute the thorium content and is international best practice. A plant to do this has been built at the LAMP and it is simply waiting for ACTUAL WLP to verify its processes.
    - You agree that the only significant exposure pathway is dust inhalation and I agree with that. The concentrate and the waste will be kept damp so it's hars to see how significant dust will be airborne.
    As for your comments on the IAEA recommendations:
    1. There are plans and they have been made public. They need to be verified when the LAMP actually produces residues and can't be signed off until then.
    2. LAMP has 20+ years to get that right. I believe there are plans submitted but don't know of a source.
    5. The fund is actually $US 50m, paid in installments. The Bukit Merah process was appaling and companies should NEVER be allowed to duplicate that. The fact is, LAMP will be closely monitored (not least by SMSL) and will never be allowed to randomly dump waste: nor should they! It IS worth noting that the Bukit Merah waste has about 70 times the thorium content of the WLP.
    8,9. It's clear that Lynas and AELB underestimated the PR downside of Fukashima which is the real source of the concerns about LAMP. I don't think that either handled it well but equally I think the vast majority of the anti-Lynas literature is complete rubbish. Lynas HAVE been trying with, for example, the "Lynas Malaysia" facebook site. Worth a visit.
    11. The follow-up mission by the IAEA would be a great idea. Given the delays in the LAMP startup (due to constantly moving goalposts) I think the ideal time would be the middle of 2013: that would give all parties the chance to provide data based on the ACTUAL LAMP operations rather than model predictions.

    As a final comment: Lynas has jumped through every regulatory hoop in Malaysia and then some (IAEA, PSC etc) and come up clean in every one. They have incorporated every one of these recommendations into their practice (way beyond what the original approvals required). If the LAMP was then to be canned I believe Malaysia would be an investment no-go zone for at least a decade, and deservidly so.

    1. Thanks for the comment. At least we both agree that LAMP is a no-go for now. :)

      Fyi, I did not include NUF and FGD in my waste volume calculation, WLP is LLW according to UK standard. But again, that will depends on the radioactivity of the actual waste (the preliminary EIA indicated 10 times higher radioactivity than IAEA report, I've taken the IAEA one as it's a more credible source). In any case, monitoring of the waste management is the issue here, not so much on 'how to do it' rather 'whether we can do it'. You can read my Part I analysis on the difference between safe on scientific paper and safe based on scientific evidence (statistical).

      I am aware of the waste recycling suggestion but doubt that there's already a waste recycling plant in place at LAMP. Lynas has not issued any statement that 'they will' convert the waste, they only said 'in the event that waste cannot be disposed abroad.... they will convert'. In fact, there's a temporary waste storage facilities in the plant (this we know). So, most likely there's no such plant. If you have information regarding the existence of such plant in LAMP, please let me know. I did not include waste recycling in my Part II analysis as there's no way that any proper argument can be raised with only news statements by the governmental bodies and Lynas without any scientific report, pilot plant proof, or real world examples. Also if there's such plant, it is quite impossible to have 100% conversion, so we'll still face with waste issue (you can read my another article on this).

      Overall, thanks for the reading the article and take time commenting on it.

    2. I am concern abut the possibility of terrorist like Al-Qeada/Sulu soldier use it to create dirty bomb or bomb the container to release radioactive material http://www.youtube.com/watch?v=2XCxKeq8nWU

  4. And I wonder who has been monitoring the LL radioactive waste at Huntsman Tioxide in Teluk Kalong, Kemaman for over 15 years already? What about the radiation monitoring at the Iron Ore Mines in Gebeng itself?

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