Lynas Malaysia, through Gading Senggara Sdn. Bhd. (an appointed operator for the Permanent Disposal Facility) has recently submitted an Environmental Impact Assessment (EIA) for a proposal to construct a Permanent Disposal Facility (PDF) for the Water Leach Purification (WLP) residue on Lot 31375, Gebeng Industrial Estate, in Kuantan, Pahang. The proposed PDF is located in a peatland and Gebeng has been identified as one of the areas prone to peat fire in Pahang and a flood-prone area. Peatland is a vital carbon sink, water reservoir ecosystem that supports unique species of plants and animals on top of providing a wide range of functions.
Aerial view of MCKIP 3 (Source: https://www.ecerdc.com.my/investment-opportunity/ecer-an-ideal-investment-destination/thematic-industrial-parks/malaysia-china-kuantan-industrial-park-mckip-3/)
The Department of Environment (DoE) is currently calling the public to take part in a public review process of this EIA. The deadline to submit comments is on 30 November 2021.
Sahabat Alam Malaysia and the Consumers Association of Penang (CAP) reviewed the EIA and sent in our comments to the DoE. Based on our review and consultation with experts, the quality of the EIA is far from adequate and does not comply with the Town and Country Planning Act 1976 (TCPA) and cannot be approved as is.
The following is among others, a summary of our concerns and comments:
- On the legal process: The proposed PDF facility has not followed the due legal process in seeking the advice of the National Physical Planning Council (NPPC), as required under Section 20B of the Town and Country Planning Act 1976.
- The classification of the WLP as Low Level Waste (LLW) in the Western Australia Environmental Protection Authority’s (EPA) report on Lynas’s Kalgoorlie Rare Earths Processing Facility (October 2021) shows the application of a double standard by Lynas. There appears to be a stricter standard for the waste classification in Australia and a less strict standard in Malaysia.
- Misinterpretation of International Atomic Energy Agency’s (IAEA) report to classify WLP as VLLW.
- The EIA report fails to take into account the climate change impact, in particular relating to the increase in monsoon precipitation and risk of flooding.
- Lack of a detailed study on building a PDF on a peat area.
- Risk of instability, subsidence and slope failure.
- The HDPE layer and PDF design do not guarantee a “Permanent” Disposal Facility
- There are serious shortcomings in the hydrogeological modelling.
- Contradictory statements in the EIA over the use of groundwater by the nearby villagers.
- The sampling of WLP Residue Storage Facility (RSF) runoff should cover dry and wet seasons to provide a more representative characterisation of the wastewater.
- The need for a full disclosure of monitoring data.
- Concern over the competency of Gading Senggara to manage one of the largest PDF in the world.
- The need for the EIA to provide more information on the decommissioning, post closure and/or abandonment plan.
The full written comments submitted to DoE can be accessed here.
We would like to encourage the public to submit your comments on or before 5pm (Malaysian time), Tuesday 30 November 2021 via an online submission form, here or you may also use the DoE’s link to provide your feedback and concerns here.