13th Sept 2011
Dear Mr Nick Tsurikov
Your letter dated 29th August 2011 and comments on my interview with TV PAS titled Perceptions – Why we must Stop Lynas is referred to. I am sorry for the late reply. It’s due to the busy schedule in Ramadhan as well as the long Eid Holidays plus the fact that some of the experts in our team being overseas. Anyway, here is the reply.
Much as I appreciate your interest in my interview, and with all due respect, I find that your comments to my interview are grossly out of order and based on many wrong perceptions of my actual response in the interview. You have misinterpreted and misunderstood many of my statements, (either intentionally or unintentionally) and in some instance, even accuse me of saying things which I didn’t.
Considering that you’ve been advising Lynas Corporation on issues of radiation, I cannot dismiss the possibility that you may have been instructed by Lynas Corporation to write to me. However, I will give you the benefit of the doubt by accepting your sincerity to discuss the issues openly with my team of experts as well as with myself.
Please refer back to the video of the interview on you tube “Perceptions -Why We Must Stop Lynas” in answer to all your issues below.
1. It was very clear in the video clip that I was referring to “No Benchmark” and “No Best Practise Guidelines” to a rare earth refinery. I was not referring to radiation alone. Furthermore I didn’t even mention the word radiation. I mentioned that there’s no rare earth refinery in operations outside China at the moment thus we do not have a benchmark neither do we have a best practise in rare earth refinery, unlike other chemical plants…
2. The China Standards: Attachment 1 – Please refer to the proposal from Lynas Corp which was presented to ?our government in the early stages. Under the title “Deportment of Radioactivity” It is self-explanatory that Lynas Corp at that time plans to get away from the responsibility of managing the radioactive waste re – LAMP by declaring that the waste from its plant is not radioactive. It was using the China Standards GB9133-88 as benchmark. Furthermore, you may have noticed that the IAEA safety standards for Radioactive Waste Classification. IAEA No. GSG-1, was not mentioned anywhere in the EIA report for LAMP neither was it mentioned by IAEA in their peer review report on Lynas. Lynas Corp had not shown any commitments in any of its documentation to the IAEA standards right from the beginning till now.
3. The statement “in Australia even to extract the rare earth elements it is mandatory for the operations to be located 35 kms from residential areas” was never ever mentioned by me. I suggest it’s best that you have a look at the video clip again. To accuse me of having misled the public on this issue and statement is grossly bad faith on your part in a situation when it was not even said by me. On other occasions, whenever I was referring to the 30 km radius, I was referring to the Mt Weld Concentration Plant, vis-a-vis LAMP which is being built in a densely populated area within its 30 km radius.
4. The discussion on the specific radioactivity is provided by our consultant Dr Lee Chee Hong – a Chemical Engineer with an expertise on metal corrosion. Dr Lee quotes that “The activity concentration of the water leach purification (WLP) solid waste is reportedly 6.2 Bq/g, (IAEA Report) this puts the LAMP’s WLP waste in the Low Level Waste (LLW) category. It is recommended by the IAEA GSG, this waste requires robust isolation and containment for periods of up to a few hundred years and is suitable for disposal in engineered near surface facilities.”
5. Please refer to the Video clip again. When I was talking about alpha, I was referring to the radiation in the context the penetration distance and it being not so dangerous in that sense. To take it out of context is so unprofessional of someone with your background and expertise. The comments about the dust have been provided by our consultant on public health. Dr Chan Chee Khoon an epidemiologist. He quotes “Equally important, current international radiation standards have yet to deal satisfactorily with the contentious issues plaguing CERRIE’s deliberations on internal emitters”
ref: ECRR 2010 (p.7):
the present radiological safety models are largely accurate for external irradiation situations involving doses greater than 100 mSv so long as the exposures are well defined and uniform, but break down where calculations involving averaging methods are used to examine non-uniform doses in microscopic tissue volumes. It is the microscopic distribution of ionizing events in tissue, from the point of view both of the external field and of the medium of absorption, which is the critical factor in radiobiological damage and this has not been modelled by the physics-based ICRP model which largely ignores molecular interactions, dealing rather with average energy transfer. (Attachment 2)
6. I am aware that MP Robin Chapple has been to see you. According to your good self Uranium waste from LAMP will be stripped in Kuantan – I am sure you can recall your conversation with Hon Robin Chapple during his visit to Lynas Corporation sometime in May. Do you realise that Balok river is just next to the Gebeng Industrial zone and it leads to the sea. Our technical team is very concerned that some of the uranium will be dissolved during the process of extraction at high temperature using acids. After the centrifugal process to separate the solid from the liquid the dissolved uranium may be discharged as part of the liquid waste. Balok River leads to the sea and Kuantan harbours one of the largest fishing port in the region with 390 deep sea trawlers registered. These are real concerns that should never be dismissed.
7. Again you are putting words into my mouth. I never said we should close all plants that produce radioactive waste. I do not think that you can ever understand the seriousness of the situation, considering that you’re based in Australia. My greatest concern is that LAMP should never have been approved to be located in Gebeng or anywhere in Malaysia. Lynas Corp have the license to operate a secondary processing plant in Meenar, Western Australia. The commitments laid down by EPA were so stringent. Why is it Lynas does not follow the same commitments here in Malaysia?
As a conclusion, In order to make a decision regarding the safety of LAMP it involves inputs from various disciplines, and not radiation alone. Once you appreciate that, then only you will understand the angle where we’re coming from.
Thank You and Best Regards,
MP for Kuantan
3 Reference Links (in PDF files):
Nick Tsurikov’s letter dated 29th August 2011 to Kuantan MP YB Fuziah Salleh: http://normreport.com/random/2011.08.29.NT-letter.pdf