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ONG KENG YONG High Commissioner, High Commission of the Republic of Singapore Level 15, West Wing The Icon, No.1, Jalan 1/68F Jalan Tun Razak 50400 Kuala Lumpur Malaysia

Re: Visit to Singapore High Commission over the Lynas Advanced Materials Plant (LAMP)
With regards to above matter, we, a group of concerned residents from Kuantan, appreciate the opportunity given to us to bring to your attention the potential health and environmental risk of the Lynas Advanced Materials Plant (LAMP) in Gebeng, Kuantan to the surrounding areas including neighbouring ASEAN countries. For the sake of brevity, we shall summarize the potential effects on Singapore in this text, and some of the justification of our assessment in the appendix. Background The Lynas Advanced Materials Plant (known as LAMP herein) will commence its operation to process enriched rare earth ore (known as concentrates herein) and yield high purity rare earth oxides. The rare earth mineral will be mined at Mount Weld, Western Australia and subsequently enriched onsite prior to trucking to Port of Fremantle, 1000 km away. The concentrates will be loaded into the 20-feet containers and commenced a 4000 km sea voyage to Singapore, where c.a. 4000 containers/year will be unloaded to smaller vessels prior to heading to the Port of Kuantan. The intended load to LAMP is approximately 65,000 tonnes/year (dry base); 80,000 tonnes/year (wet base). The rare earth oxides are inherently harmless, however, two elements bound with the rare earth to form the ore, are radioactive, i.e. thorium and uranium. Waste Generation Scenario The LAMP processes require substantial amount of chemicals and reagents, such as sulphuric acid, magnesium oxide, hydrochloric acid and utilities such as raw water and natural gas. These are required to extract the rare earth oxides and to generate copious amount of wastes including three types of gypsum, i.e. Flue Gas Desulphurisation (FGD), Water Leach Purification (WLP) and Neutralization Underflow (NUF) residues, flue gas and waste water. In other words, operations cannot start and continue without the creation of waste. It is the intention of Lynas to purge almost all radioactive materials (thorium and uranium) and to channel them to a sole waste stream, known as WLP. The radioactivity concentration in the other 4 waste streams is regarded as either non-detectable or negligible. The table next page summarizes the characteristics of each waste stream:

Waste stream Waste water Flue gas NUF residue FGD residue WLP residue

Amount 500 tonnes/hour 99,344 Nm3/hour 177,820 tons/year 58,920 tons/year 64,000 tons/year

Radioactivity Negligible Negligible Total activity 0.52 Bq/g Total activity 0.47 Bq/g Total activity 62.3 Bq/g

Disposal method Discharged into Balok River, which leads to the South China Sea Discharged through smoke stack into the atmosphere Commercialized as fertilizers Commercialized as gypsum board Commercialized as road building material, failing which it will need to be permanently isolated

The commercialization of the wastes is still in the R&D stage. There is no indication that there are any interested buyers for these recycled products. Even if there is, there are serious implications of such disposal methods, as products containing trace amounts of radioactive elements will be sold throughout Malaysia, and possibly Singapore. Lynas intends to commence operation while figuring out what to do with the waste. In the meantime, they will store the solid residues on-site in open storage ponds, as they have not yet identified the Permanent Disposal Facility (PDF) where the radioactive wastes are to be buried. We are very concerned that LAMP poses real risk of contamination because: 1) the site of the plant is on a reclaimed swamp land, and the underground water table is merely 0.95 - 3.5 m below surface. 2) the low-lying area is prone to flooding due to the monsoon rain. 3) the New York Times reported serious construction and design flaws that "have the potential to cause the plants critical failure in operation" [1,2]. 4) the half-life of the primary source of radioactivity, i.e. thorium-232 is 14 billion years. This may result in the accumulation of radioactivity over time from "negligible" sources We feel, therefore, that the LAMP will bring serious repercussions to the people of Malaysia and Singapore. It may affect Singapore via these scenarios: a) Food security Kuantan is a major seafood producer with 390 registered deep sea trawlers. Significant seafood caught in Kuantan ends up in Singapore. Radiation risk may spread across border through radioactivity accumulated in the food chain. b) Other sources of contamination Other pathways may come from products that are made with contaminated materials, for example, palm oil, birds nest, fruits and vegetables, as well as Lynas' proposed products that are made with their wastes. The US found out the consequences of using gypsum board made with FGD-type residue, and had in 1989 banned the use of this product. Also, the US EPA also noted that the use of fertilizers made with NUF-type residue can increase the radioactivity of the produce [3]. Lynas must not be allowed to spread their pollution.

c) Risk from transporting the raw material through Singapore According to the RIA, 65,000 tons per annum will go through Singapore in 4000 containers annually. Lynas has disclosed that the payload will be sealed inside double layered plastic bags. It will be transported as non-radioactive but as soon as it touches down in Kuantan, it is classified as radioactive. This is due to a legal loophole in Australia's Dangerous Goods Act. The construction of the bags are not known. We do not know how robust they are. A spill may be disastrous to the environment. d) Deterrent to Malaysia's nuclear ambition Due to its size, Singapore will probably not pursue nuclear power due to these power plants becoming strategic targets in times of war. This leads to Singapore being unfairly subjected to radiation risk from its neighbors' nuclear ambitions. If Lynas is allowed to proceed, and the Malaysian public buy the "radiation safety" propaganda, nuclear plants will be next in line. If we stop Lynas now, the government will not dare to proceed to nuclear plants due to the political risks. Malaysia is capable of harnessing renewable energies and Malaysia's wet climate is not suitable for nuclear repositories according to IAEA's guideline [4] . The people of Malaysia and Singapore don't need any more radiation risk and it is in Singapore's interest that the Malaysian public remains averse to it. Finally on 1/3/2012, a few days after the 15,000 strong green rally against Lynas, a Singaporean academia Professor expressed doubt over the safety of the plant [5]. Given Malaysia's poor record in construction reliability, the most memorable one is the collapse of the roof of a newly constructed stadium in Terengganu, nobody trusts the incompetent Malaysia government to manage such a high risk venture. We hope that the Singapore government agrees that the Lynas project is a reckless industrial experiment, and we hope that your honorable commissioner can do everything within your diplomatic power to persuade the Malaysian government to abandon this project.

Yours sincerely,

______________________________ Dr Lee Chee Hong (Technical Advisor for Himpunan Hijau 2.0) Chin Yee Kaing, Clement (Himpunan Hijau 2.0 PR chief) Lee Chean Chung (Himpunan Hijau 2.0 publicity chief) Nasrun Amir Abdullah (Himpunan Hijau 2.0 event coordinator) Soo Jin Hou (Technical Advisor for Himpunan Hijau 2.0)

[1] "The Fear of a Toxic Rerun", New York Times, by Keith Bradsher, June 29 2011. [2] "Rare Earth Metal Refinery Nears Approval", New York Times, by Keith Bradsher, Jan 31,2012 [3] "Phosphogypsum and Imported Drywall" from http://www.nuclearcrimes.org/phosphogypsum.php [4] IAEA, "Near Surface Disposal of Radioactive Waste", No. WS-R-1, 1999, pg 14. [5] "", 1/3/2012.