oeko report

My thoughts on the OEKO institute report:

Follow this link if you would like to read the lot, http://www.oeko.de/oekodoc/1628/2013-001-en.pdf
My advice is skip the lot and read the conclusions at the end which capture the whole 114 pages, whilst an interesting read it confirms to me that LYNAS is leading the way when it comes to establishing itself as the “test case” (if I could call it that) of processing rare earth. Opening comments by Gerhard state both the intentions of SMSL and OEKO to prove that LAMP is not “state of the art”, note state of the art not whether the plant is safe or not.

In order to prove their case this study has compared LAMP against worst case scenarios/ hazardous substance incineration plants/ hypothesis etc whilst plainly stating that there is no real comparison for LAMP as it is the only of its kind. Also virtually the fact that it needs to be operational before anyone can accurately calculate real time emissions etc
Virtually the only thing this OEKO report could be scathing about is what to do with the waste. Which is yet to be cleared up completely and required the issuance of the TOL to acertain, SMSL clearly jumped on this to stoke the fires of their verbal garbage.

Below are some lift outs I found comical: (brackets my own opinion)


(Sounds slightly bias already)
This report was prepared after visiting the site and its neighborhood. The author wishes to express his thank for the reliable help of SMSL in getting documents and background information together, for the numerous open talks with Malaysians fa-miliar with the issue and all the friendly assistance to the European expert in order to better understand local perceptions, fears and expectations.
Understanding the perceptions of SMSL did influence, but did not determine the expert work performed here or its results. The work was done completely inde-pendently, as is tradition at the Oeko-Institute and is required and guaranteed by its statute.

(example of no real information available for rare earth processing)
3 E.g. IUPAC’s, the physicist’s and chemist’s union, includes those two elements in their REE defini-tion.
4 LD50 determines the mass intake (e.g. as milligram per kg) that causes death to half of the test animals.
Toxicity
Although they are rather abundant, /Paul 2011/ describes the threats of rare earth elements as follows:
“The threats to human health and the environment from radionuclides are well known, but the threats from rare earth elements are equally unknown. The movement of rare earth elements in the environment is generally lacking. The toxicology of rare earth elements to aquatic, human, and other terrestrial or-ganisms is not well understood either. The toxicological effects would largely depend on the rare earth element compound and the dose of that compound.”
Biological effects and clinical findings such as those listed in /Bastarache 2012/, animal experiments with rats to determine LD504 values /Bruce 1963/, research Critical Assessment LAMP plant Lynas 13 Freiburg, Darmstadt, Berlin

among persons that were affected by elevated REE uptake such as /Zhang 2000/ and compilations of toxicity studies in order to determine risk factors such as /TERA 1999/ show that the toxicity effects are manifold, and depend upon the chemical form and the application mode (chronic vs. single application, lung vs. ingestion, etc.).
The following can be concluded from this literature:
• As to current knowledge, the toxicity of REEs is low to medium and comparable to other metals.
• Currently no indications are given on cancerogenic and mutagenic effects.
• As there are known toxicological effects and as the knowledge on their distribu-tion characteristics via water- and bio-pathways is limited, emissions of these metals to air and water shall be limited and carefully monitored.

(So virtually you have to sit on top the ore 24hours a day 7 days a week 365 days a year to exceed the safe work level)
3.1.3 Gamma doses and dose limitations
The gamma rays, emitted during the decay, can easily be detected. In the vicinity of the ore concentrate a gamma dose rate of 2 to 3 µSv/h can be measured, adding up to approx. 26 mSv/a if a person were to stay for a whole year (8,760 h/a) in this vi-cinity (see the following chapter on dose and risk). This dose would
• slightly exceed the adopted protection level for workers of 20 mSv/a,
• exceed accepted protection levels for the general public from the controlled emissions of nuclear installations of 1 mSv/a by a factor of 26,
• be by a factor of roughly 8 larger than average doses from natural sources (mainly caused by inhalation of natural radon-226 and its decay products), and
• be by a factor of 260 larger than 10 µSv/a, the accepted dose for practices where risks are considered well below any regulatory concern.

(this mainly surrounds the radon and sulphuric acid leaving the stacks, I love the dig at the Malaysian Environment regulation that it is not good enough, whilst LYNAS must meet the Malaysian regulations…note again it does not say that it is safe it says “not state of the art”)
3.2.3 Environmental consequences
The resulting doses from the release of radon-220 and radon-222 in the cracking stage of the facility over the stack of up to 0.16 µSv/a are indeed “trivial”. Even if the identified differences and inconsistencies in chapter 3.2.2, esp.

•?The environmental consequences from the emission of radon over the cracking facility’s stack are small.
• Even when introducing more strict assumptions in the dose calculation the as-sociated dose and risk remains negligible.
• Small risks should be communicated as such. They should not be compared with natural background, because the natural background risk level is not zero and is not always below acceptable levels, based on given current knowledge and understanding. Such comparisons are in most cases un-scientific and mis-leading.

•?the static Malaysian environmental regulation in respect to air quality is inap-propriate, because it neither reflects improved knowledge on adverse toxicolog-ical effects nor does it encourage to the application of improved technical capa-bilities to reduce emissions; the regulation should be improved by adopting dy-namic limits taking advantage of technical improvements,
• the treatment systems of Lynas for abating emissions of acidic gases and acids as well as for dust are neither state-of-the-art nor best-available-technology and causes sulfuric acid emissions that are too high by a factor of at least two and PM10 dust emissions that are too high by an even larger factor.