By Rama Ramanathan | March 13, 2012 The Malaysian Insider
MARCH 13 — The written word doesn’t make faces. Technical reports don’t include snide remarks. International experts don’t publicly reveal some of what they’re really thinking. I wonder what the International Atomic Energy Agency (IAEA) experts were really thinking when they said:
“The 1-2 tons bags of the rare earths concentrate will be transported by road from Mt Weld to Perth (or a nearby port) in 20 ton land-sea containers. From Perth, the containers will be moved on ships to Singapore. From Singapore, smaller vessels will move the containers to Kuantan. Up to Kuantan, the rare earths concentrate will be shipped as normal non-radioactive material, in accordance with international regulations. From Kuantan port, the containers will be trucked 15 km to the Lynas facility in Gebeng. Malaysian regulations require the concentrate to be treated as radioactive material.” [Adapted from IAEA International Review Mission (29 May – 03 June 2011) Report, page 27.]
Do you get it? According to international standards, the material can be handled like any soil. Then, when it lands in Malaysia, “it’s radioactive.” It’s like saying Australian apples are safe worldwide, but not in Malaysia.
This for me is the Lynas dilemma.
When businesses choose locations for factories, their engineers carefully study the regulations. If I had been on the Lynas-Gebeng project team, I would have said we must have rocks in our heads if we wanted to locate our plant in Malaysia. Malaysia’s atomic energy regulations are stricter than elsewhere!
Yet Lynas chose to build its plant in Malaysia.
The IAEA Review team had 5 IAEA staff members and five international experts. On their flight home in June 2011, these 10 people must’ve been wondering what they were going to say to their colleagues when they got home.
The fact is, the material being moved by road and sea is NOT radioactive according to international regulations. I suspect it’s required to be treated as radioactive when it lands in Malaysia because the Malaysian regulator, the AELB (Atomic Energy Licensing Board), is being cautious.
I understand the AELB’s caution. As a quality manager I often placed strict requirements on suppliers when they began to supply me: we both knew that based on data we would later review the requirements. This is standard practice, even when the vendor has an excellent track record. If I was a member of the IAEA team, I might explain AELB’s “bizarre requirement” as a ‘we will tolerate no nonsense’ message to Lynas which has no track record.
The IAEA team offered another explanation. Their report reveals that the Malaysian regulations haven’t kept up with the times. The current Malaysian Transport Regulations are based on the 1985 IAEA Transport regulations, which were revised in 2009. Also, the Malaysianisation of the 1985 regulation failed to maintain the distinction between radioactive ‘material’ and ‘product.’ In the words of the report:
“[The] broad definition [in the Malaysian regulation] covers all material that surround us in everyday life even at background or trivial levels.” [page 28]
The report wryly recommends updating of the regulations.
I’ll move on to discuss the solid residues (‘product’), of which there are three streams: FGD (Flue Gas Desulphurization) residue, NUF (Neuralisation Underflow) residue and WLP (Water Leach Purification) residue. The following quote makes clear that in the opinion of international experts, the FGD and NUF residues — which make up about two thirds of all the residue — is not dangerous from the radioactive point of view:
“The radionuclide concentrations in the FGD and NUF residues are expected to be very low — similar to the average values in normal rocks and soil worldwide (and in Malaysia).” [page 17]
Experts don’t loosely use terms like ‘very low.’ The IAEA team is really saying “What lunacy! Why doesn’t the AELB just say these materials are not radioactive? Why did Lynas choose to build this plant in Malaysia?”
Yet Lynas chose to build its plant in Malaysia.
So, despite the fact that according to current Malaysian regulations everything is radioactive, is there some waste from Lynas which is truly a matter of concern, vis-à-vis radioactivity? [I am focusing on radioactive waste because this is the primary reason activists are giving for opposing the Lynas plant.]
The answer is a qualified yes; qualified, because it needs a context.
The context can be grasped from what students in Edinburgh used to say about people from Aberdeen, Scotland. We said Aberdonians glowed in the dark, because the background radiation in Aberdeen is about double the national average — because of all the naturally occurring granite, much of which was used to build homes. And we said Aberdonians who were vegans were more radioactive because they ate lots of beans to make up for the proteins they chose not to get from milk and cheese. And beans are the most radioactive food you can eat.
Context matters. As the report puts it:
“The WLP contains relatively low concentrations of naturally occurring radionuclides and the hazards are equally low.” [page 20]
Note the experts carefully said: ‘Relatively low.’ The imported concentrated ore has an activity level of 6 Bq/g (Becquerel per gram). The WLP residue is expected to have an activity level of 6.2 Bq/g (page 16). But, surprise! The WLP is treated as radioactive! [I suppose because it’s a man-made product, and thus subject to more variation than natural processes.]
As mentioned in the report, the WLP residue can be ‘recycled’: it may be possible to safely add it in small proportions to other materials, without compromising safety: I know this is hard to believe, especially after the ‘recycling’ antics of Asian Rare Earths in Bukit Merah. But those who live in a house built with WLP-added concrete may not be exposed to risks greater than say the Aberdonians. [Trials will be needed in order to develop and tweak the blending process.]
If the blending technology proves unworkable or if there is no market for the blended product, the WLP waste will have to be stored long-term. This is why the IAEA team has asked the AELB to require Lynas to supply a comprehensive plan for managing the waste long-term – in case this option is necessary.
Yet, the AELB says it may require Lynas to return the residue to its source: is it going to become safer after it retraces the journey to Mt Weld? Or is this prudence on the part of the AELB, and a strong incentive for Lynas to develop a reliable process to re-use the WLP waste? Or does the AELB now have cold feet? Or is the AELB bowing to political pressure?
This is what Lynas gets for choosing to build its plant in Malaysia.
I know there’s more to be considered, e.g. why give a temporary license, what about worker safety, why we need the IAEA to tell the AELB what to do, etc. My purpose is not to provide a full treatment of the Lynas issue, which I think exemplifies how high-handed and non-consultative our government is.
My purpose is to lament a painful truth.
We know Umno-BN must have benefited much from the Lynas project because Malaysians have benefited little, if at all. We know we can’t trust our government. We don’t believe AELB will do a good job of enforcement. We criticise international experts who don’t say what we want to hear.
This is the state of Malaysia after 54 years of Umno-BN rule. Is this what the IAEA experts were thinking on their way home in June 2011?