FEEDBACK TO AELB 26th January 2012 DOCUMENT Doc 1 & 2 1.

Classification of Radioactive Waste Lynas claims that their WLP Solid waste does not fall under any of the 5 classes of Malaysian classes of Radioactive Waste Lynas falls back to the IAEA classification of Radioactive Waste and claims that its waste is VLLW-LL (a category which is not one of Malaysian classes) Going by the Malaysian classes, then Lynas waste will be classified as LLW-LL Lynas goes further to use the IAEA classification to justify landfill type of facility disposal for its WLP Solid Residue Lynas must not be allowed to do this. Refer to the UK chart where the limit for VLLW-LL is at 4 Bq/g. Going by UK standards then the WLP Solid Residue from LAMP will be LLW-LL; thus will have to be disposed of in a near surface facility, and not in a landfill type of facility as proposed by Lynas Refer to UK classification of waste attached. ULASAN CADANGAN

DOCUMENT

ULASAN

CADANGAN

Doc 1 Classification of Radioactive Waste and method of disposal

UK classifications of Radioactive Waste specifies that VLLW are waste that can be disposed of with ordinary refuse. IAEA classifications of Radioactive Waste specifies that VLLW-LL are waste that are normally soil and rubble from nuclear plants. However the IAEA GSG -1 (12) does not specify the limit or cut off point for each classification Classification of Radioactive Waste Management does not refer to the radioactivity alone. Please Refer to Comments on IAEA Peer Review Report by Dr Lee Chee Hong (pg 15-16)

The Australian Radiation Protection talks about Radioactive Waste Management from the cradle to the grave where Radioactive Waste Management means the whole sequence of operations starting with the generation of waste and ending with disposal. ARPANSA also describes typical waste from VLLW class as soil and rubble with low activity concentration level http://www.arpansa.gov.au/radiationprot ection/RadioactiveWaste/sequence.cfm Refer to IAEA Safety Series SAFETY SERIES No. 111-G-1.1

DOCUMENT Doc 1 & 2 Permanent Disposal Facility Taking into the benchmark of a Uranium Mill Tailing type of facility

ULASAN

CADANGAN

Refer to Best Practice in a Rare Earth Refinery www.oeko.de www.resourcefever.org To use a Uranium Mill Tailing as a benchmark to justify for a The Study on Rare Earth and their Recycling January landfill type of disposal facility is also very irresponsible on the part of Lynas. (This is one way for Lynas to get away with proposing 2011 landfill type of facility since the IAEA waste management allows for Pages 56-58 compare between Mt Pass Rare Earth Refinery plant to the Lynas plants the uranium mill tailings to be disposed of in landfill types of Its interesting to note that the thorium and uranium facilities ) contents in the ore in Mt Pass is slightly less than that present in the ore from Mt Weld, but we can see that On a closer look uranium mill tailings are where the extraction of the Waste Management Plan is more stringent uranium activities leave behind some radioactive materials Refer to nature of Uranium Mill tailings http://www.wiseAlso refer to Molycorp Waste Management Plan uranium.org/rup.html. available online from their website www.molycorp.com However rare earth extraction is where the rare earth elements are extracted, leaving behind the thorium and uranium as waste. The content of the thorium and uranium in the concentrate all comes out as waste in one form or another

DOCUMENT Doc 2 Safety Case Permanent Disposal Facility

ULASAN It was mentioned that Lynas is considering to have the PDF on an island where there is no inhabitants This must never be allowed as the leachate from the PDF can leach into the sea. Considering the radionuclides have a half life of 14 billion years, then it is feared that the leachate will harm marine life a few hundred years down the road.

CADANGAN The responsibility of the permanent waste disposal facility must be undertaken by the government and not be trusted entirely to Lynas. Lynas will be gone after 20 years after they have made tones of profits and the future generation will have to be burdened with the responsibility of the disposal facility. As in the case of ARE, the public is exposed to it a long time after Mitsubishi Corporation has left the country However the criteria for siting of a Permanent Waste Dsiposal Facility according to the Best Practise is almost impossible considering the availability of groundwater everywhere in Malaysia.

Exposure Pathways to the Hazardous Material RESRAD 6.5

Lynas mentioned RESRAD 6.5 in calculating the dose measurement for the radiological exposure to the WLP solid waste through external radiation, soil ingestion and inhilation However the safety case document were lacking in the calculation of the other exposure pathways to the

A proper Health Impact Assessment is necessary and should have been part of the process in granting the License to operate to Lynas

hazardous materials through other means

DOCUMENT Doc 1 & 2 Location and Siting of LAMP in Gebeng No Industry is 100 % efficient

ULASAN LAMP is constructed on peat soil, swampy area where the water table is barely 1 meter below the surface. Its located near the Sg Balok, by the South China Sea and houses nearby residents within 3 km radius of the plant. Furthermore Cherating which is a tourist destination with beautiful beaches is located just within 10 kilometers of the plant.

CADANGAN The Precautionary Principle must surely apply in the safety case for LAMP What if there is a leakage as in the case of UNOCAL There were incidence of 60 unreported leakages from Molycorps rare earth plant (previously

Unocal) in the late 90s Amongst the residents that live nearby are employees of the other factories in the Gebeng Industrial Plant as well as local residents some of them are fishermen The location and siting of LAMP makes it too risky to approve of operating license even though on a temporary basis. In the event of an accident or when there is a leakage, its impact will be too disastrous to the environment. What if Lynas did not comply to the specification of their process in Gebeng? Considering Lynas did not comply to the thickness of their RSF lining in Mt Weld. It was mentioned in the renewal of their license dated 1st April 2011 Ammended Work Approval (Environmental Assessment Report pg 4 of 21 )