LYNAS CEO Amanda Lacaze is evidently unaware of the lack of consensus among radiobiologists and radiation safety specialists regarding the health risks of chronic, low-level exposure to ionising radiation from internal emitters.

The “safe thresholds” of 1 millisievert/year (public) and 20 millisievert/year (occupational) that Lynas, AELB, and IAEA repeatedly invoke are pragmatic recommendations on dose limits from the International Commission on Radiological Protection, which relies on quantitative risk models largely calibrated against external sources of instantaneous irradiation of large human populations, most importantly, the long-term follow-up studies of survivors of the Hiroshima and Nagasaki atomic bomb blasts, as well as patients subjected to medical X-rays.  

Whether these risk models are adequate for assessing the health risks of chronic exposure to low-level ionising radiation from ingested or inhaled radioactive particulates (notwithstanding periodic updates and refinements) remains contentious, especially in the wake of excess childhood leukaemia near nuclear power plants that could not be explained by radiation exposures which were two to three orders of magnitude below the “safe thresholds”.

Most notably, two large epidemiological studies in Germany (KiKK, 2008) and in France (Geocap, 2012) have reported statistically robust findings of a doubling of leukaemia risk among children living within a 5km radius of a nuclear power plant, where radiation exposures were much below 1 millisievert/year.

Could the excess leukaemia be due to inhaled or ingested radioactive particulates not satisfactorily accounted for in ICRP’s risk models?  A UK expert panel (CERRIE, 2004) could not arrive at a consensus regarding the health risks of low-level exposure to these internal emitters.

Opinions among the UK panel’s members ranged from negligible adverse effects to an underestimation of risk by up to tenfold (see for instance a four-page summary by CERRIE panel member Dr Philip Day on why health risks of internal emitters need to be fundamentally re-assessed. http://www.bandepleteduranium.org/en/docs/97.pdf).

Could the excess leukaemia be due to electromagnetic fields associated with high voltage power cables linked to the nuclear power stations? Or to population mixing and vulnerability to infectious agents suspected of causing leukaemia? No one can be sure.

In other words, nobody really knows at this point how safe (or hazardous) the Lynas refinery may be, given that much of the radioactive solid wastes are in powder form, i.e. respirable when dry as suspended particulates, or ingestable from contaminated surfaces.

At the Kuantan public hearings on November 11, 2018, Tan Bun Teet underscored the need for a secure (flood-proof) permanent disposal facility with his photographic blow-ups of an inundated residue storage facility, which dispelled any notions of dependable housekeeping and sequestration of radioactive wastes at the Gebeng refinery site.

When experts in radiation safety disagree among themselves, the precautionary principle becomes even more important in public health practice. Let’s recall that obstetric X-rays were considered safe by the medical and scientific community until the 1950s, when Professor Alice Stewart (Oxford) raised the alarm with her findings of increased risk of childhood leukemia. These findings were initially also dismissed as a fringe minority opinion – by Sir Richard Doll, no less, doyen of cancer epidemiologists and Regius Professor of Medicine at Oxford – but Professor Stewart’s persistence eventually saw them incorporated into mainstream medical practice.

In reiterating that the LAMP refinery is in compliance with the relevant local laws (notably, AELA 1984), Lacaze is either unaware of the unresolved debates over internal emitters, or is being cavalier with the precautionary principle, in contrast with California, United States, for instance, where Molycorp had to comply with a zero liquid wastes discharge requirement, or in Germany, where popular will obliged Angela Merkel to phase out nuclear power plants even as scientists and researchers continue to lock horns over the unexplained excess of childhood leukaemia in the vicinity of nuclear power plants and nuclear reprocessing facilities.

Most pertinent to the LAMP refinery perhaps is the case of another Australian company, Arafura Resources Limited, and its proposed rare earth operations in Australia, as an illustrative example of how the precautionary principle is operationalised there.

The Natural Resources, Environment, the Arts and Sports Department of the Northern Territory government had the following conditionality for the issuance of an operating license: “Tailings produced from the off-site processing of ore (i.e. processing waste) are proposed to be transported back to the mine-site for long term storage. The processing waste will contain radioactive material (e.g. thorium)”.

In plain language, the radioactive solid wastes produced by Arafura’s mining, ore concentration, and refining processes were to be returned to the originating mine-site at Nolans Bore (near Alice Springs, NT) for secure burial.

In accordance with principles of environmental justice, it was considered unfair to burden the residents of Whyalla, South Australia (location of the proposed rare earths refinery) with anxieties over their community’s health.

Applying the same standard of precaution to the LAMP refinery at Gebeng would require that Lynas return its radioactive solid wastes to its originating mine-site at Mt Weld in western Australia.

We recall that the Asian rare earth refinery at Bukit Merah, Ipoh, like LAMP, had very opaque long-term waste management plans, if any. Ad hoc arrangements, including the aborted Papan dump-site, eventually led to a situation of indiscriminate open dumping of radioactive thorium-cake wastes at Lahat, Menglembu, Pengkalan, Jelapang, Buntong, and Simpang Pulai, among other locations.

It would be sad if the Kuantan-Kemaman community ended up as “tikus makmal” (lab rats) in a natural experiment. – December 6, 2018.

* Chan Chee Khoon reads The Malaysian Insight.