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1 ACTION PLAN FOR WLP RESIDUE MANAGEMENT (2018)

ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

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Page 1: ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

1

ACTION PLAN FOR

WLP RESIDUE

MANAGEMENT

(2018)

Page 2: ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

2

Lynas Advanced Material Plant (LAMP) generates TWO major residues

1. Water Leached Purification residue (WLP)

a. produced from the precipitation of post leaching liquor with MgO

b. is primarily iron phosphate, with minor iron hydroxide, aluminium hydroxide and

gypsum.

c. Contains Thorium at activity concentration of about 6 Bq/g

d. Classified as radioactive material by the AELB

e. Defined by the IAEA as A Very Low Level Radioactive Waste

2. Neutralization Underflow (NUF)

a. is a solvent extraction and product finishing raffinate neutralized with lime

b. NUF is also known as Mg rich synthetic gypsum as it is primarily gypsum

c. is a SW205 regulated by the DOE, Malaysia

Page 3: ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

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NUF @ MRSG WLP

Content % wet wt Content % wet wt

Gypsum

Ca2SO4.2H2O

73-74 Iron phosphate

FePO4.nH2O

25-50

Magnesium hydroxide

Mg(OH)2

17.1 Calcium carbonate

CaCO3

5-25

Calcium hydroxide

Ca(OH)2

4.2 Phosphogypsum

(Ca,P)SO4 (H2O)x

1-10

Calcium carbonate

CaCO3

2.3 Uranium oxide <0.01

Silica (amorphous) Si 0.4 Thorium hydroxide <0.2

Chemical compositions of WLP and NUF

Page 4: ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

4

Lynas Zero Harm subscribes to National and International BEST practices in residue management

Lynas’ vision of “Zero Harm” and comprehensive approach to sustainability self-regulates

Lynas to adopt the best practicable and innovative environmental strategies for reduction of

residues generated. This is in line with:

a) International waste management principle of from “cradle to cradle”

b) The IAEA 9 fundamental Principles of Radioactive Waste Management, specifically

Principle 7: Control of radioactive waste generation: Generation of radioactive

waste shall be kept to the minimum practicable.

c) The 8 principles of Malaysia’s National Policy on the Environment which sought to

harmonize economic development goals with environmental imperatives.

Specifically, Principle 3: Continuous improvement in the quality of the environment

through Malaysia’s Green Strategies of prevention and control of pollution and

environmental degradation, i.e. the reuse and recycle of residues over their

permanent disposal

Page 5: ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

5

Lynas strategy in residues management

Safe and Secure Storage

R&D Commercialization

Page 6: ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

6

WLP residue regulated by the AELB

▪ The IAEA categorized the WLP as Very Low Level Radioactive Waste

▪ WLP residue, contains Thorium-232 at activity concentration of about 6 Bq/g

▪ WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity.

▪ The AELB approved Lynas PDF Planning Framework on 24th Oct 2013

▪ TWO options in residue management were agreed;

1. To commercialize the use of WLP.

2. To store WLP in permanent storage facilities as waste.

▪ Lynas has deposited USD 34 million to date with the AELB as a security deposit.

The IAEA categorized the WLP as Very Low Level Radioactive Waste

Page 7: ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

-7-

Action Plan in Residue Management:Residues are currently stored in storage facility that is designed and

constructed to meet PDF standards

CONTROLLED

FILLDUAL LINER

SYSTEM

POLYETHYLENE

(HDPE) LINER

CLAY LINER

SCARIFY AND

RECOMPACT

PLACED AND

TRAFFIC

COMPACTED

WLP

RESIDUERAISES OF

CONTROLLED

FILL

EXISTING

GROUND

LEVEL

EXISTING

GROUND

LEVEL

EROSION

PROTECTION

DETAIL

Dual liner consists of a 300 mm low permeability compacted

clay liner overlaid with a 1.0 mm thick HDPE linerThe RSF is built on top (not excavated!!)

Page 8: ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

8

Lynas has an EXTENSIVE and FOCUSSED R&D Program on the Commercialization the WLP

▪ Between financial year 2013 – 2017 Lynas spent RM 25 million or more than 0.5 % of the gross sales annually on R&D related to residue management.

▪ Lynas engaged and collaborated with local and international experts, research institutions and laboratories to carry out comprehensive R&D

▪ Institutions such as MARDI, Nuclear Malaysia, UPM, UKM, UMP, Univ of Western Australia, Golders report, ANSTO, SIRIM, DOA lab, Dept of Chemistry Lab, AsiaLab etc

▪ All R&D projects are guided and approved by the AELB and DOE

▪ R&D carried out at laboratory, plot, and large scale trials

▪ R&D involved potential clients/users like Lembaga Kenaf danTembakau Negara, plantation and farmers etc

▪ All research findings are reported to the AELB and the DOE.

Page 9: ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

9

Product Development Trials

Page 10: ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

10

Products Characterization and Applications

▪ PRODUCT: CondiSoil : blend of WLP: NUF: filler material

▪ PRODUCT CHARACTERIZATION for specialized and accredited labs:

▪ Non-toxic

▪ Non-carcinogenic

▪ Non-ecotoxic

▪ Non-radioactive

▪ NON-HAZARDOUS

▪ PRODUCT APPLICATION:

▪ Soil conditioner: Product meets Malaysia’s standard for soil conditioner and fertilizar, quality specifications determined by DOA (MS 2523:2013)

▪ Alternative Backfill Material: engineered material

Hazardous Tests and Testing Facilities Date

Golders Report concluded NUF is non

hazardous

June 2014

SIRIM reported NUF and CondiSoil as

non-hazardous and meet Special Mgt of

Scheduled Waste 205

Nov 2014, June

2015

AELB classified CondiSoil as non-

radioactive

July 2015

SIRIM, DoChem, MARDI, DOA reported

CondiSoil meets DOA MS1517:2012 –

Organic fertilizers specification (1st

Revision)

MARDI: April 2017,

DoChem: April 2017,

DOA: April 2017

SIRIM reported CondiSoil non-hazardous

according to Special Mgt of Scheduled

Wastes

Aug 2017

Page 11: ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

11

Where are we in CondiSoil Commercialization?

▪ All commercialization R&D implemented are guided and approved by the regulators before being implemented.

▪ Progress and successes of all of commercialization R&D were reported to all relevant regulators (AELB, DOE,

MOH, DOA) and presentation were made to Ministries (MOSTI and NRE)

▪ Applications for THREE Special Management projects of residue/product (including WLP), the final step

before commercialization, were submitted for approval to the regulator to the DOE. 1ST letter sent 15 June 017

▪ ONCE APPROVED, Lynas will start commercialization.

▪ Lynas commercialization R&D has clearly provided an opportunity for the adoption of best practicable means to

use and reduce its residues safely.

▪ This is in line with the important principle in waste management of from cradle to cradle encouraged by the

DOE and world bodies.

Page 12: ACTION PLAN FOR WLP RESIDUE MANAGEMENT - Lynas · WLP can be used productively therefore should NOT be classified as a waste but a residue or by-product with very low level radioactivity

12

Action Plan for WLP Residue Management

Commercialization R&D

completed & reported to

Regulators

Applied for Special

Management

AELB, DOE, MOD, DOA,

SIRIM, MARDI, MOSTI,

NRE

DecisionYES

CommercializationNO

PDF site selection

On-site PDF

Off-site PDF

AELB: ON-site is

preferred because:

a. More viable and

accurate design of

PDF

b. Experience from

WLP RSF

c. IAEA

recommendation

Temporary

secured and

safe storage of

residues

DOE: Secured

landfill