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

2

• 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

3

Mount Weld Mine – Western Australia

- Mine contains average 9% Rare Earth, soil,

organic matter, rocks, sand, various

minerals and 0.04% thorium + uranium

trucked to concentration

plant, 1.5 km awayConcentrates will

be trucked 1000

km to Port of

Fremantle

> 4000 km voyage from Port of

Fremantle to Kuantan (via Singapore),

approx 65,000 tonnes per year of

concentrates will be delivered.

LAMP, Gebeng, Kuantan

Mt. Weld Concentration Plant

To produce ore contains primarily

monazite, with c.a. 40% rare earth

Finished Products: Refined

rare earth up to 99.9999%Wastes produced

- Waste water

- Waste gas

- Three types of Gypsum

(FGD, WLP, NUF)

11,000 tonnes in the 1st year;

22,000 tonnes/yr subsequently

FEED :

- Concentrates at 40% REO

and contain 0.17% Thorium

& uranium

4

5

Rare Earth OxideMt Weld

Distribution2008 2009 Q4 2010 Q1 2011 20/06/11 18/07/11

Lanthanum Oxide 25.50% $8.71 $4.88 $52.49 $75.87 $140.10 $153.00

Cerium Oxide 46.74% $4.56 $3.88 $52.62 $77.52 $150.60 $159.00

Neodymium Oxide 18.50% $31.90 $19.12 $81.38 $130.23 $330.00 $320.00

Praseodymium Oxide 5.32% $29.48 $18.03 $78.62 $119.65 $235.50 $250.00

Samarium Oxide 2.27% $5.20 $3.40 $36.58 $72.75 $135.60 $130.00

Dysprosium Oxide 0.124% $118.49 $115.67 $287.85 $412.90 $1,470.00 $2850.00

Europium Oxide 0.443% $481.92 $492.92 $611.54 $719.20 $3,400.00 $5880.00

Terbium Oxide 0.068% $720.77 $361.67 $620.38 $717.60 $2,800.00 $4520.00

Mt Weld “basket” price $14.87 $10.32 $62.18 $92.84 $203.69 $223.78

* Lynas’ official websites

Radiation

(alpha, beta and

trace of gamma)

External Internal

Radioactive

decay

products

Radioactive

materials

6

• 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

7

Few meters to few tens of meter

Alpha Ray. Travel distance < 10 cm

Beta Ray. Travel distance < 100 meter

Radioactive

materials

8

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.

9

continue …

10

Feedstock scenario

Concentrated ore (Feedstock to LAMP) contained :

0.16% Thorium oxide

0.0029% Uranium oxide

Lynas claimed

WLP waste :

0.1655% Thorium oxide

0.00225% Uranium oxide

Other :

neg. % Thorium oxide

neg. % Uranium oxide

11

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.

Feedstock scenario

12

1600 ppm Thorium

29 ppm Uranium

FEED

Waste gas

WLP

FGD

NUF

Waste water

12 ppm Thorium

0.3 ppm Uranium

c.a. 6 ppm Thorium

neg ppm Uranium

neg Thorium & Uranium

neg Thorium & Uranium

neg Thorium & Uranium

Process

1655 ppm Thorium

22.5 ppm Uranium

Atmosphere

Recycled,

reused?

Stored onsite

Recycled,

reused?

Sg. Balok -> Sea

Atmosphere, water streams

Wastes scenario

• 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 – didn’t 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 dust13

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

14

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 background15

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??”

16

“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). 17

Scope of the Review

• To provide recommendations

• The review only cover (IAEA, p3, para 2):

a) Radiation protection – Chapter 2

b) Waste management – Chapter 3

c) Decommissioning and remediation – Chapter 4

d) Transport – Chapter 5

e) Safety assessment – Chapter 6

18

Scope of the Review2. 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

19

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 non-

compliances with the International radiation

safety standards

• Identified 10 issues, which to be dealt with 11

recommendations

20

11 recommendations1. 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 non-

radioactive

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.21

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)

22

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.23

IAEA’s 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

24

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.

25

26

Radiological Waste Classifications

27

24/Jul/11 28

Near surface:

Typically from surface down to 30 meter

24/Jul/11 29

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??

30

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

31

• 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

32

ACT 304

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.

33

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.

34

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))

35

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 don’t want a review that didn’t cover the entire aspects of the RE

refinery process

• We don’t want a review that assumes zero radioactive material release to

the environment

• We don’t want a report that review only the CONSTRUCTION phase –

hypothetical, imaginary

• We don’t a review that relies entirely the data/ information provided by

Lynas – lack of impartiality and autonomy

• We don’t want a plant that is loosely regulated and controlled.

• We don’t want the LLW to be lying in an open space in Gebeng.

• We don’t want to jeopardy our health and environment as a result of the

approval of the plant by this report.36