In response to our press statement on the renewal of the Full Operating Stage Licence for another three years, Lynas now claims there is no need for a Permanent Disposal Facility ( PDF) in view of their field trials and the possibility of commercialisation of their ‘solid residues from Lamp’.
This is a gross misrepresentation of the facts though the term ‘solids from Lamp’ is technically correct.
1. The Lynas Advanced Materials Plant (Lamp) produces three kinds of solid ‘residues’ (Lynas preferred the term residues to that of wastes because they claim that these ‘residues’ can be recycled), the first of which is called FGD (Flue Gas Desulphurisation). This together with the NUF (Neutralization Underflow) ‘residues’ are not classified as scheduled wastes as they are not radioactively potent.
The third category of waste is called WLP (Water leached Purification) ‘residues’ which are radioactive as it has a radioactivity of 6.4 Bq/gm.
It is the last category of ‘residues’ that the IAEA recommended to have them stored in a Permanent Disposal Facility.
2. The broad statement that ‘field trials and commercialidation of their ‘solid residues from Lamp’ does not differentiate between the radioactive one from that of the non scheduled wastes. Even if the field trials and commercialization is viable for the radioactive WLP ‘residues’, the need for a PDF would still be required as the decommissioning of the plant will require it to be identified and built.
3. It is both technically and financially not viable to recycle the radioactive WLP ‘residues’ as has been pointed out by us in our memorandums to both the Atomic Energy Licensing Board (AELB) and the Lynas Operation Monitoring Committee (LOMC) prior to Lynas’ first Temporary Operating Licence (TOL) renewal in 2014.
The simple reason being to turn the WLP ‘residues’ into commercial byproducts with less than 1 Bq/gm (so as to be classified as ‘non radioactive’), the costs are too prohibitive. Many other industries had abandoned the idea of recycling their industrial wastes even though theirs are non-scheduled wastes.
4. Lynas is not in any financial position to start recycling any of their ‘solid residues’ now or in the near ‘future’ as can been seen from their yearly financial report. The FY 2016 report is currently overdue.
5. Lynas claimed that currently it has produced 93,300 tonnes of WLP ‘residues’ on dry weight basis. To use this quantity of WLP ‘residues’ before they can be ‘recycled’ into ‘non-radioactive products, it would require a six-fold volume of whatever substance that could be used to dilute it before they can become the feedstock for the industrial product.
‘Preliminary costs practically make recycling impossible’
6. The preliminary costs of drying the WLP pastes before dilution practically make the recycling impossible. All claims on the reuse and recycling of WLP ‘residues’ were put up merely for the sole purpose of acquiring renewals for their Temporary Operating Licence.
7. The need to identify and build a PDF is recommended by IAEA in their 2011 report. Even in their second report (2015) it did not rescind the call to dispense with the PDF. It merely expressed its opinion that the ‘radioactivity’ of the WLP residues was ‘intrinsically low’. (That was after it took them a full month’s delay to ‘describe’ the radioactivity of WLP as ‘intrinsically low’).
8. They have also disclosed that they have submitted a siting plan and an engineering plan for the PDF ‘in accordance to the regulatory requirements’.
This statement underscored the remark made by the former director-general of AELB in 2014 that Lynas had only submitted a ‘conceptual plan of the PDF’ and he further commented that it was not acceptable.