The Radiological Impact assessment (RIA) for the Lynas plant which was made available for public viewing on 30 May 2011 has cast serious doubts on the whole approval procedure and due diligence process.
Firstly, the RIA made public recently was done in June 2010. However, it made references to an earlier version approved in 2008.
Why was the RIA approved in 2008 before the revised version was completed in 2010? Can an approved RIA be later updated, post-approval?
How does this reflect on the integrity of the RIA process and the due diligence process? Why is the originally approved 2008 version not in the public domain?
Most importantly, there is a critical omission in that the scope of the RIA does not cover future decommissioning of the plant, nor the final wastes disposal plan.
Only a reference to an AELB Guideline (LEM/TEK/38) is made for decommissioning and cessation of operations. What is this AELB Guideline? Is it legally binding? What are the necessary legal checks and balances to ensure that the decommissioning and cessation will not leave a toxic legacy like the Asian Rare Earth factory did in Bukit Merah years ago?
Page 49 of the RIA shockingly revealed that its assessment of storage capacity of radioactive residues is only for ten years. ‘Assessments beyond 10 years will not be looked at in this study because the residue streams are going to be in the RSF (Residual Storage Facility) only as an interim measure as the Company has a plan to consider other alternatives for final disposal of residues.’
The RSF is only an interim measure but the RIA was approved? What does this say about the current due diligence and governance process? Note that Lynas is expected to be in operations for at least 20 years (page 37). In the first ten years alone, the Lynas plant will produce some 824,400 cubic metres of radioactive wastes residues (page 38). Thus, the Lynas plant has no known credible waste management plan during the ten years of storage AND has no final permanent disposal and decommissioning plans. As the RIA does not cover final wastes disposal, what will happen to all the accumulated wastes and the contaminated factory? How does one get rid of these radioactive and toxic wastes? Who is liable and who pays?
Other major concerns regarding the RIA include facts such as:
• The MNA (Malaysian Nuclear Agency) which did the RIA for Lynas reveals that ‘the concentration of thorium 232 in Malaysian soils varies around (0.09+_0.05 Bq/g)’ (page 30). Thus, compared to the PEIA-reported radiation value for one of the wastes planned for use as construction materials and fertilisers (page 66) having a much higher radiation value of 62 Bq/g, the cumulative radioactivity will definitely increase the background radiation levels in Gebeng and the surrounding areas. Thus, what is the use of the specially designed RSF, the plastic lining and clay layer during storage?
• The RIA states that ‘two of the TENORM (radioactive wastes residues) are expected to contain enhanced concentration of TENORM and are potential to cause some impact to the people involved’ (page 32). Note that the AELB permissible radiation exposure dose limit is 1mSv/year for the public and non-radiation workers, while the dose limit for radiation workers is up to 50 mSv/year. However, the new IAEA is more stringent than AELB, as it recommended radiation exposure limit for radiation workers at 20mSv/year (page 35). According to the RIA, the first group of Malaysian workers potentially affected by external radiation as well as internal radiation from breathing in lanthanide dust during loading and unloading will be the Kuantan port workers and the truck drivers. Similarly, the workers at the plant itself will be affected, especially the workers at the Water Leach Purification (WLP) wastes area.
• To prevent leaching of radionuclides (radioactive substances) the storage cells dual liner system consisting of a 1mm plastic liner and a one foot clay layer is grossly inadequate as the plastic liner can be punctured and the clay layer can crack due to subsidence of peat soil. Moreover the plastic layer will degrade with time (page 63 and page 5-58 of the PEIA).
The RIA concludes that the operation of the ‘plant would not cause undue radiological risks to workers and the public’ (page 71). To claim this is irresponsible when the scope of the RIA does not cover more than a ten year period; does not include long-term wastes storage and disposal problems; and does not address the decontamination and decommissioning plans.
The RIA for the Lynas project shows the dire lack of due diligence, compliance and enforcement wherein basic procedures and rules were not even adhered to. This cavalier approach has meant that public safety and environmental issues have not been sufficiently addressed. In fact the regulatory authorities have shown that they are incapable of safely monitoring the Lynas operation, the wastes storage, disposal & decommissioning process in the future.
Due to the factual proofs of lack of due diligence already from the beginning, and the factual scientific proofs of the dangers of radioactive wastes, the announcement by the Minister of MITI yesterday (New Straits Times, June 20, 2011, read here.) is not very convincing. As it is, MITI is not the qualified ministry for the governance of ultrahazardous radioactive activities and public health and safety concerns. Again, this shows the poor governance and lack of due diligence in the whole process.
Press release, 21 June 2011