FPE 3223

ENVIRONMENTAL IMPACT ASSESSMENT (EIA)

SEPTEMBER 2018/2019

EVALUATION REPORT: PROPOSED

ADVANCED MATERIALS PLANT GEBENG
INDUSTRIAL ESTATE, KUANTAN,
PAHANG, MALAYSIA

FACULTY AND PROGRAMME: FSB – SEN3, SEL4

LECTURER: DR. AMAL NAJIHAH BT. MUHAMAD NOR

PRACTICAL GROUP: 9
No Students Name Matrix No
1 Liew Kar Fai E16A0076
2 Chong Li Weng E16A0040
3 Gan Hui Kee E16A0060
4 Wong Shi Yun E16A0306
5 Wallace Lee Tian Zhu E16A0297
6 Nur Fathin Afifah bt Mah Hassan E16B0179
7 Nisrina Nadia bt Maizatul@Maizatu E15A0139
8 Syafiqa Jauna Mohamed Jefry E15A0282
 TABLE OF CONTENTS

No Task Page

0 Executive Summary i -ii

1 Introduction 1-2
2 Statement of Need 3-5
3 Project Description 4-6
4 Project Option 7-8
5 Existing Environment 9-10
6 Potentially Significant Impact and Mitigation Plan 11-12
7 Residual Impact 13-14
8 Environmental Monitoring 15-16
9 Conclusion 17
10 References 18
11 Appendices 19-20
12 Discussion Conduct 21- 24
EXECUTIVE SUMMARY
Name: Nur Fathin Afifah bt Mah Hassan E16B0179

Executive Summary provides a summary of the key findings of the EIA study. This report
presents the evaluation of the Environmental Impact Assessment of the development of the
proposed Advanced Materials Plant on Gebeng Industrial Estate (GIE), Kuantan, Pahang. This
project undertaken by Lynas Malaysia Sdn. Bhd. which is a fully owned subsidiary of Lynas
Corporation Ltd of Australia, which is an integrated producer from mine to customer of refined
Rare Earth products for global markets. Lynas Corporation Limited identified Malaysia as a
viable location for the siting of their proposed Advanced Materials Plant based on economic
and infrastructure considerations. Lynas Corporation Limited identified Malaysia as a viable
location for the siting of their proposed Advanced Materials Plant based on economic and
infrastructure considerations. Lynas has commissioned ENVIRON Consulting Services (M)
Sdn. Bhd. to conduct a preliminary Environmental Impact Assessment of the proposed
Advanced Materials Plant within the GIE. Completion of the construction phase is expected to
be in June 2009 at which time plant operations will commence.

The proposed Advanced Materials Plant in Malaysia is to process the lanthanide to

produce a suite of products comprising individual lanthanide elements or mixtures of elements
which can be used directly in selected industries or subjected to further downstream processing.
Lanthanides demand was assumed continuously growth with the increasing usage in permanent
magnets, consumer electronics and automotive catalytic converters. This project had encourage
investor from other country to invest on establishment of Lynas. It also contribute to the
strengthening of industrial linkages and enhancement of productivity and provide employment
opportunities to local Malaysian.

Whole EIA report comprise eight chapter discussed about the project description and
option, existing environment, environmental impacts and mitigation measure, residual impacts
and emergency response plan. The description of existing environment is based on both
primary and secondary data. The GIE where the proposed plant site is to be located on 100 ha
of industrial land within the Phase III area of the Gebeng Industrial Estate (GIE) in the Mukim
of Sungai Karang was also formerly part of the the Paya Tanah Merah peat swamp forest. It
was also located within the catchment of Sungai Balok. The data of noise levels, ambient air
quality, soil and groundwater quality and the water quality of Sungai Balok were collected.
Riverbed sediments were also collected and analysed for heavy metals, and plankton and
macrobenthos biodiversity.

This study has identified the potential impacts to the surface water, soil and
groundwater, environmental noise, solid waste, ambient air, biological resources, socio-
economic issues and traffic and tansportation from the development of the projects on Lots PT
8249 and PT 13637 within the Gebeng Industrial Estate (GIE). The relevant legislation and
standards governing these issues which are applicable to the project are also discussed. The
potential sources of impact are identified based on construction and operational phase.
Mitigation measures were identified to manage and control the predicted impacts to a
sustainable level and to comply with the requirements of the Environmental Quality Act, 1974
and its subsidiary legislation have also been recommended. Environmental Management Plan
(EMP) required to ensure environmental objectives are met and operations are carried out in
an environmentally sustainable manner. This required for both construction and operation
phase. Environmental monitoring was conducted on water quality, boundry noise, air quality
and also soil and groundwater. Overall, the finding from EIA report indicated that
environmental impact from this project can be mitigated and reduced.
1) INTRODUCTION

Name: Liew Kar Fai E16A0076

1.1) Description of the Project

Lynas Advanced Materials Plants, or known as LAMP for short, is a rare-earths

refinery plant that located in Gebeng Industrial Estate (GIE) in Kuantan, Pahang, to refine the
Lanthanide ores mined from Mount Weld, Australia. The project is owned by Lynas
Corporation. Ltd., a rare-earths mining and refinery company. A Preliminary Environmental
Impact Assessment (PEIA) was done for the project at the selected location. Detailed
Environmental Impact Assessment said not needed due to ‘ore-processing’ activities are not in
the requirements of EIA prescribed activities and the location is a gazetted industrial area.

1.2) Description of Main EIA Report

The report is done by a Malaysian environmental consultancy group, ENVIRON

Consulting Services Sdn. Bhd., making an EIA with 9 specialists and 2 companies and
laboratory for environmental monitoring and laboratory tests, along with Lynas’ Malaysia
subsidiary. The report consists of 8 chapters, including introduction and conclusion of the
report. The content of the report consists of project concepts, project options, emergency
response plan, environment management plan, and potential impacts with its mitigation plans.
The report also presented its limitations while reviewing it for reference.

1.3) Review of the EIA Report

The review of the report was done by the members below and the tasks given were included:

Name Given Task/Review Parts

Chong Li Weng Project Descriptions and Project Options
Gan Hui Kee Environmental Monitoring
Liew Kar Fai Full Report, Introduction, Conclusion,
Appendices
Nur Fathin Afifah bt Mah Hassan Full Report, Executive Summary
 Nisrina Nadia Maizatul Potentially Significant Impact and
Mitigation Measures
Syafiqa Jauna Mohamed Jefry Residual Impact
Wallace Lee Tian Zhu Existing Environement
Wong Shi Yun Statement of Need

The review of the report was done to understand the project in detail, while viewing for the
improvements and further options and recommendations for the project and the report. The
evaluation for the PEIA report was done with no biases included.

1.4) Limitations on the Review

As there are some official reports are confidential, most of the review done on the report are
based on the public informations, the report, and its official site along with publicly accessible
data and reports. However, this situation does not affect the creditability of the evaluation
report as opinions and informations of all sides has been taken in consideration. It is
recommended that the projects full EIA report and side notes to be disclosed and openly
accessible to the public to increase the understanding of public to the project.
2) STATEMENT OF NEED

Name: Wong Shi Yun E16A0306

2.1 Global Lanthanides Market Demand

Based on the data shown in 2005, global demand for lanthanides is about 95000 metric tons
and expected to exceed 154000 metric tons by 2010 with 10% of growth per year. Lanthanides
usage also assumed to be increase with increasing of lanthanides application such as permanent
magnets, consumer electronics and automotive catalytic converters. Demand growth is more
distinct in automotive industry as more hydraulic systems are replaced electric components
and more NiMH rechargeable batteries are used in hybrid vehicles. China is currently dominant
supplier of lanthanides which support about 95% of lanthanides market. However, extraction
of lanthanides from China will probably due to recent implementation of regulatory control,
thus become a costlier location. Hence, the proposal by Lynas to commercially mine the
lanthanide deposit and process it in Malaysia, into the various elements is therefore timely and
justified.

2.2 Industrial Development in Pahang, Malaysia

One of the core economic sectors in Pahang is Industrial development. Pahang State
Government established necessary promoting mechanism in this development especially heavy
industries, iron and steel industries. East Coast Industrial Development (ECID) Corridor is a
new growth area especially for rapid industrial development in Terengganu, Pahang and
Kelantan. Gebeng is one of the key growth centres for ECID as it is close proximity to centre
of ECID which is Kuantan. Gebeng was envisaged to become one of the Malaysia lead
industrial hub to feed domestic industries demand. Hence, the setting up of the LAMP project
within the ECID not only complements the vision and aspirations of the State Government but
will also encourage the growth of other supporting industries within the locality which will
lead to overall positive socio-economic benefits.

2.3 Positive Socio-Economic Impacts to Malaysia

2.3.1 Inflow of Foreign Direct Investment

The estimated proposal investment is same with efforts of government to encourage foreign
direct investments into Eastern Corridor of Malaysia. The estimated total capital for the
proposal is about RM 550 million while its operating cost is RM 2.8 billion for the first 15
years. Hence, Eastern Corridor of Malaysia with such high capital investment will benefit
Malaysia in way of job opportunities, development of relevant industries and infrastructure
development. In order to improve this part of report, the relevant industries in this statement
should supported with example. The beneficial effect should elaborated with stronger evidence,
as the expected inflow does not fully shows the benefit received by the corporation and for the
targeted country.

2.3.2 Export Revenue - Foreign Exchange Earnings

For the first 15 years, high purity lanthanide product from Advanced Materials plants is able
to contribute RM 9.5 billion as an export revenue. This profit drives significant cash inflow
into Malaysian economy and spur growth of whole country not only Eastern Corridor.
However, the expected exportation partner should be listed here as a mode of trade
transparency, and to confirm that the chosen partner do not offending the policies of Malaysia.

2.3.3 Transfer of Technology

Lanthanides processing in Malaysia introduce new technologies and expertise to Malaysia

while this industry is currently most dominant in China. Lynas owns propriety technology for
lanthanide minerals recovery from ores which will be applied in proposed plant. Meanwhile,
Lynas will adopt state of art solvent extraction equipment and process technologies for
lanthanide elements purification and separation. Transfer of technology take place as employee
training in Australia or foreign technical specialists provide training to local staff. Besides,
Lynas plans to collaborate with Universiti Malaysia Pahang (UMP) and conduct research and
development activities with both local and foreign expertise. This helps to improve knowledge
and skills of local workforce. The concern about the statement is, do the company wish to share
the core skills and technology in order to truly achieve the technology transfer, and clarification
is needed on this statement.
 2.3.4 The Growth of Supporting Industries and Surrounding Areas

The plant is expected to strengthen linkage of industry and enhance productivity through
integration of activities. It aims to transform manufacturing sector in Eastern Corridor into
resilient and international competitive sector. Especially, focusing on cluster development
through deepening and broadening of inter-linked and related activities enhance
competitiveness of manufacturing industry. East Coast Corridor expect to develop related
activities such as chemical, water, transport or logistics and more through operation of Lynas
plant in Gebeng.

2.3.5 Employment Opportunities

To enhance skills and industry knowledge on lanthanide processing, Malaysian employee are
trained and guided by expatriate employees. This is to enable local employees to take over
responsibilities with sufficient skills and technical knowledge. The need of local employee
result in increasing job opportunities for Malaysians. Job opportunities in manufacturing sector
of Eastern Corridor is not only required for lanthanide industry but also chemical, gas and
petroleum, water and etc. The expectation of proposed plant is to employ 398 local Malaysian
and 20 foreign employees as guider in the first operation year.

2.3.6 Economic Benefits

The proposed plant in Malaysia is expected to be multiply beneficial to economy of Malaysia.

The expected contribution of proposed plant to Malaysian economy in the first operation of 15
years is about RM6.04 billion. This includes direct and indirect contribution with multiplier
effect factor of 2. Besides, tax revenue of RM 42 million are generated by Lynas proposed
operations in Malaysia.

*Remark: The statement of need of the project and the report has fulfilled the requirements of
National Physical Plan of Malaysia in developing the country towards First World state. Thwe
only problem that needed to clarify is the information on benefits of FDI inflow to both sides.
3) PROJECT DESCRIPTION

Name: Chong Li Weng E16A0040

2.1) Project Phases and Surveying Techniques

The project contains 3 phases: pre-construction phase, construction phase and operation phase.
The report also stated that, geotechnical investigation, topographical surveying, and multiple
methods was used to find a location which is suitable to build the plant as minimal
environmental impacts and risks to the local resident. The company also agreed in the report
for making wastewater output planning, radioactivity test for the refinery plants, and
environmental impact tests when the operation is started.

2.2) Review on Pre-Construction Phase

Pre-construction phase will be focusing on obtaining physical data on the existing

conditions at the project area, which includes geotechnical investigation; land topography
survey; identification of ecological resources; environmental baseline monitoring for ambient
air quality, river quality and boundary noise levels; while lastly, soil and groundwater
investigation. These tests were considered as suitable as the tests involves land, water, and air
tests. However, due to the nature of rare-earths where it contains radioactivity, radiation tests
is needed on the raw materials and productions, or providing a strong data/evidence to proof
the plant is safe and not causing big impacts.

In geotechnical investigation and topographical survey, the data was obtained for use in
earthworks preparation, infrastructure planning, plant design platform level and residue storage
facilities planned within the site. Due to the above activities, some removal of the undergrowth
and shrubbery was necessary and these actions are completely disrupting the ecosystem in
shrubbery area, it also destroy the habitat of some mammals, insects, reptiles and also birds.
During baseline survey, the existing terrestrial ecology at the site was also evaluated by
monitoring of ambient air quality and boundary noise levels at the site in order to minimize the
environmental impacts arising from this project.
2.3) Review on Construction Phase

Construction phase includes setting up and management of temporary facilities;

clearing of vegetation and undergrowth; excavation and disposal of unsuitable foundation
material; site preparation works including filling and formation of platforms; infrastructure and
utility development and landscaping. However, land clearing is one of the most non-eco-
friendly action as the proposed plant site has been largely cleared. This destroy the ecosystem
and the natural habitat for species that live in that area. However, there is no other option than
land clearing as it is necessary for construction purposes.

During construction, transportation of building materials and machinery will be

transported to the site by low loaders and heavy load bearing transport vehicles. The movement
of these vehicles may cause traffic congestion and traffic jam will affect the air quality. Because,
car burns the most fuel while accelerating to get up to speed, hence, the slower moving traffic
emits more pollution than when cars move at freeway speeds (Hermes, 2012). Next, the
drainage network within the site will be designed to transport through unlined channels, the
site drainage will be designed to lead into a storm water detention pond located close to the
southern boundary of the site. Although the detention pond will find its way into the existing
external earth drain, however, this pond will cause flood to occur during peak rainfall. Thus, it
is recommended to show in the report that what mitigation plans will do if such matters happen.

2.4) Review on Operation Phase

Operation phase includes the concentration process and also cracking and
separation process. On utilities part, all waste streams generated from the advanced materials
plant will be either recycled within the process or treated in a wastewater treatment system
prior to discharge, which is eco-friendlier. In the report, the corporation has agreed on
maintaining water quality of its surrounding, and will release wastewater management data to
proof the plant are handling the wastewater properly. The report also showed the quality of
wastewater to see if the effluent is suitable for discharge.
 4) PROJECT OPTION

Name: Chong Li Weng E16A0040

3.1) Location Options

There are few site selections initially, which is China, Abu Dhabi and Malaysia. The reason
why Lynas wanted to locate the plant outside Australia was based on economic considerations
as the isolated location of the mine site resulted in a very high capital costs for plant and
infrastructure construction. Not only that, consider the costs of operation such as cost of
shipping reagents and transporting labour force is very high. Hence, they wanted to invest the
plant in another more suitable area.

3.2) China

At first, they wanted to choose China as China has more expertise and technologies in
lanthanide processing. But the decision was reversed due to the result of Chinese Government
wanted to impose export quotas on ores that are shipped in from outside China for processing,
which also eventually increase the operation costs.

3.3) Abu Dhabi

Besides, Abu Dhabi was also one of the choices for Lynas. However, the main reason forn not
proceeding the project in there was because the political and government issue that happening
in Abu Dhabi. Their lack of transparency with respect to the project approval made Lynas to
reverse their decision. It is a concern that the statement about the country’s transparency can
cause misunderstanding between countries. A stronger evidence is needed in the report to proof
the statement is true.

3.5) Malaysia

At start, Lynas Corporation was choosing industrial zone in Terrenganu. But due to the
industrial zone are heavily focused on chemical and petrochemical industry, while there are
also no suitable facilities for ore-processing activities, there relocated their plant to Gebeng
Industrial Estate (GIE) in Kuantan, Malaysia. According to the report, the reasons that why
they choose Malaysia, are due to strategic location; accessibility to key infrastructure and
available utilities; availability of local suppliers and also availability of skilled workforce. The
Gebeng Industrial Estate (GIE) is part of the growth corridor earmarked for rapid industrial
development in the East Coast States: Kelantan, Terengganu and Pahang. So, the plant within
GIE in Pahang has high potential markets to Australia, China, India, Indonesia, Japan Qatar,
Saudi Arabia, South Korea and the United Arab Emirates. Meanwhile, due to the high port
facilities, airport, road network, rail network, natural gas supply, power supply and water
supply, Malaysia become the decision as the available of key infrastructure and utilities.
 5) EXISTING ENVIRONMENT

Name: Wallace Lee Tian Zhu E16A0297

5.1) Zone of Impact (ZOI)

In this report there are description of different aspects of environment with the Zone of Impact
(ZOI) which represents the sector within a 5km radius of the plant site. The components of
environmental concern are highlighted as well including site settings, climate and meteorology,
land use within the ZOI, human environment and environmental baseline investigation which
are important in establishing the baseline condition prior to the implementation of the proposed
project within the Gebeng Industrial Area, Kuantan, Pahang.

Regional land use pattern within a 5km radius of the proposed project is analyzed and presented
in table form showing the radial distance from the centre of site (< 1km, 1km – 3km and 3km
– 5km) and different directions (North, South, East and West) for the current land uses within
the ZOI. GIE and its connectivity to airport, port and Kuantan town area is reported and its
management is responsible by Pahang State Development Corporation (PASDEC) which
develops this industrial area in four phases (Phase I to IV) with the details tabulated. The
residential settlements located nearby the GIE are reported in Human Environment with
reference to the data from Department of Statistics Malaysia. The environmental baseline data
is also investigated based on the prevailing noise levels, ambient air quality, soil and
groundwater quality and the water quality of Sungai Balok. Heavy metals, plankton and
macrobenthos biodiversity are also analyzed from the riverbed sediments collected as well
using suitable methodology for different specimens and parameters and the results were
accessed and their secondary data are obtained from Alam Sekitar Malaysia Sdn Bhd (ASMA).

5.2) Land use

The project site in this proposal is a parcel of industrial land located centrally within the Phase
III area of the Gebeng Industrial Estate (GIE) which is on a flattened hill area of Bukit Tanah
Merah, a topographical survey shows the ground level of the site has 0° overall natural gradient
and ranged 7.4m and 7.8m above mean sea level. Information of general geology, soil and
hydrogeology of the site and the surrounding area indicates that the surface soils are alluvial in
nature and comprise mainly of peat, with addition of soil debris brought down by rivers nearby.
Besides, there are various types of rocks observed during site observation such as Arenaceous
sedimentary rocks and basaltic rocks, GIE has underlying bedrock formed by granite which is
reportedly viable in composition and texture but is commonly porphyritic, medium grained
biotite. This information is further explained in Site Investigations in 3 classifications (fill
materials, alluvium and weathered bedrock) of geotechnical site investigations.

5.3) Water Resources

Water resources of GIE comes from 2 main rivers which are Sungai Balok and Sungai
Tunggak which serve as western and eastern catchment respectively. Climate and meteorology
of Malaysia are explained in this assessment including the rainfall distribution patterns,
temperature, relative humidity, seismology, wind flow regimes and monsoon seasons, with the
reference of data from Malaysian Meteorological Service (MMS) station.

5.4) Ecology

For ecology aspect, there is no vegetation of ecological significance was observed as

the proposed plant site has been largely cleared and filled with to the existing platform level.
The socio-economic environment of Kuantan is covered with information about the area size,
populations, districts and administrations, labour workforce and pathway of effluent discharge
and its effects. Port of Kuantan is also covered with its history, connectivity with other facilities,
authorities, and the overall functions and operations. Road network between GIE and other
significant destinations such as port, airport and Kuantan town and also within GIE are
described as well.

*Remark: This part has a clear view on Malaysia’s environment condition. Details needed are
written in the report properly.
 6) POTENTIALLY SIGNIFICANT IMPACT AND MITIGATION MEASURE

Name: Nisrina Nadia Bt Maizatul@ Maizatu E15A0139

6.1 Review on the Report Chapter

The report chapter is completed with details and pointed out clearly for everyone It
included details on the arising impacts from the operations and the recommended mitigation
measures to minimise the adverse impacts toward human livelihood and environment as well.
The report also includes several standard and regulations on the limit of heavy metals or any
matters that is under permissible limits to be discharged. The several standards and regulation
that have been mentioned are, National Interim Water Quality Standards for Malaysia
(NIWQSM), Environmental Quality (Sewage and Industrial Effluent) Regulations and many
other manuals. However, the facts that this report using all standards, manuals and regulation
which is based in Malaysia is really promising.

6.2 Potentially Significant Impact

The report chapter has clearly mentioned the potentially significant impacts of the
projects from the beginning until end. It has been discussed in the report that there are three
categorized of impacts which are the short-term, long-term and permanent impacts. The short-
term impact is the impact that would be happened during the construction phase and could
cause immediately, for example contaminated runoff. The long-term impact is the impacts
which are chronic in nature, for example soil erosion and the permanent impact is the impact
which result in a permanent change to existing environment resources in the vicinity of the
project, for example climate change. This report does discuss all about the significant impacts.

Besides, operating some projects will affect human health and also environments such
as surface water, the atmosphere and others. Surface water might be contaminate because of
the discharge of effluent from the factory and the atmosphere might be polluted as well because
of the gas emission from the factory which these examples of activities might be resulting in
human health problems. Hence, this report does mention and discussed about this highly and
vulnerable issues which will give an overview to the readers.
6.3 Mitigation Measures and Impact Assessments

The report chapter also discussed on the mitigation measures that should be applied into
considerations. The quality of the surface water will be frequently checked and the discharged
of the effluent from the site or factory is under permissible limit complies with the National
Interim Water Quality Standards for Malaysia (NIWQSM), Environmental Quality (Sewage
and Industrial Effluent) Regulations. The quantity of the heavy metals that is discharged from
the effluent must be complies with the standards as there will be an action taken by the
Department of Environment (DOE) or any authority towards the irresponsibility activities.

Furthermore, the report also highlights on the impact assessments that can be
categorized into three main impacts which are physical impacts, chemical impacts and also
biological impacts. Hence, all the assessment are well discussed and put into details care as this
mining activity from the company is very high risky and will be going through several huge
impacts mainly because of the extractions. However, with this well written report showing such
a great projects that is controllable and the things that are taken could be given back to the
community and also environment as well such as economy incline and others.

Finally, the report also showing all the approach and methodology of the operation
process which is likely safe to be used and also the data and result assumptions that the
discharge from the projects is complies with several Malaysia standards such as Water Quality
Standards and the effluent then will be treated by the Waste Water Treatment Plant (WWTP).
Besides, the report also describes in detail about the process of WWTP which are aeration,
coagulation and flocculation, sludge processing, wastewater storage and exit, water recycling
and also water testing.

*Remark: The report chapter is complete and well describe about the idea that will be taken
into actions. The chapter has written and discussed all important matters with details. It also
elaborated and highlighted all the potential significant impacts that could have risen up from
the operation and also the mitigation measure that can be used to control the problems.
 7) RESIDUAL IMPACT

Name: Syafiqa Jauna Mohamed Jefry E15A0282

Residual impacts are, in the simplest sense, the consequences of any action. In a business
context the term usually refers to either residual impacts upon stakeholders or the environment.
One of the reasons to examine residual impacts of major business actions is to help mitigate
negative consequences and take credit where credit is due for positive contributions to the
community.

7.1 Review on Residual Impacts

The LAMP Project claims to be the world’s largest rare earth refinery project. It is estimated
that it will import 66,000 tonnes of ore concentrate from Australia every year and process the
ore to yield about 22,000 tonnes of high purity rare earth metals, which will then be exported
to the United States, Europe and Japan where they will play a strategic role in high technology
industries for manufacturing consumer goods, such as computers, mobile phones and hybrid
cars. Such industrial projects generate enormous volumes of toxic and radioactive waste and
are linked with serious environmental pollution and health risks. Since LAMP is located in a
densely populated, industrial area, it is important to understand it’s residual impacts to the
people, economy, and the environment.

It is important to understand the health effects of ionising radiation. Human beings are exposed
to radiation from both natural and man-made sources, but massive doses of ionising radiation
will damage tissues which the symptoms can be evident within days after exposure. To relate,
Lynas Corporation was said to have a track record on improper disposal of radioactive waste.
They produce enormous amounts of toxic and radioactive waste. The production of every tonne
of rare earth metals will generate 8.5 kilograms (18.7 lbs) of fluorine, 13 kilograms (28.7 lbs)
of dust, 9,600 – 12,000 cubic metres of waste gas (containing dust concentrate, hydrofluoric
acid, sulphur dioxide and sulphuric acid), 75 cubic metres of acidic waste-water, and about one
ton of radioactive waste, including thorium and uranium. A proper plan of disposing such waste
is seriously needed, and the report proposed a plan, which is discussed in the next subsection.
7.2 Residue Storage Facillities (RSF)

The three waste streams containing wastes, which should be classified as “long-living low
radioactive and hazardous wastes,” will be stored on-site in dedicated facilities, called “Residue
Storage Facilities (RSF). The poor design of the liner system of the RSF will include the use
of a single barrier, instead of independent multiple barriers. This will not guarantee safe, leak-
proof storage of radioactive and hazardous waste.

In fact, the report has made an astounding finding and identified such a danger: “The potential
leaching of trace metals, including radioactive lanthanide metals, from the residues may result
in contamination of the underlying soil and groundwater resources.” The design of the RSF
facilities is therefore technically inappropriate because it does not prevent leakage. It will allow
radioactive and toxic wastes to leak and enter the natural layers of earth under the Lynas facility
and reach the groundwater table. It will therefore be impossible for the Lynas plant to contain
such radioactive contamination of the environment. (Contributor, 2013).

In addition, the process will use up and pollute 500 tonnes of clean water every hour. This
enormous volume of polluted water will then be discharged into the Balok River and will
eventually contaminate the South China Sea. But the report also have data to support that such
situation will not happen. A stronger evidence and larger survey is needed to proof the above
situation will not happen.

7.3 Residual Recycle and Residual Impacts to the Environment

In the company’s official website, they also stated that the radioactivity level of the wastes are
low, and will be recycled for further use. The plant produced two types of waste, Neutralization
Underflow Residue (NUR) and Water Leached Purification Residue (WLP). Both wastes are
said to be useful to agriculture and able to make radioactive free products from it. But the report
does not properly stated the effects of these waste, and a proper clarification is needed.
 8) ENVIRONMENTAL MONITORING

Name: Gan Hui Kee E16A0060

8.1) Water Quality Monitoring

The monitoring assessment will be done on both construction phase and operation phase. The
monitoring indicators used in construction will be Total Suspended Solids (TSS), oil/grease,
dissolved oxygen (DO), biological/chemical oxygen demand (BOD and COD), pH, and
temperature. The involved water source, Sungai Balok, was monitored along its 15 km length.
The tests will be done during high and low tide period. Extensive monitoring will be done on
the first six months of the construction and staggered to once every quarter until construction
is completed. The concern for the monitoring intensity is needed attention, as the impact of
construction to the environment can be serious. Thus, it is recommended that the monitoring
can be more extensive along the construction until the plant section has been completed.

During the operation, if the discharge do not comply to environmental standards, it will be
halted immediately. The effluent, before discharge, will be monitored and the assessment will
be done on daily basis. The effluent also will have the previously stated parameters tested. Any
spills happened in the effluent pond will also have a response plan as stated in Emergency
Response Plan of the report.

8.2 Boundary Noise Monitoring

The monitoring assessment will be done on both construction phase and operation phase.
Boundary noise levels will be recorded at four monitoring stations (N1, N2, N3 & N4) which
represent the prevailing noise levels along the site boundaries (four corners of the site). As the
site is located within the Gebeng Industrial Estate (GIE), the surrounding receptors are
generally industrial facilities. Noise data will be recorded over a period of 24 hours at 15
minutes interval at each monitoring station and the integrated noise levels in terms of LAeq,
LAmax, LA5, LA10, LA50, &LA90& LA95 will be calculated. It is recommended that
boundary noise monitoring be carried out monthly during the first six months of the
construction phase and thereafter once every quarter subject to confirmation from DOE Pahang.
8.3 Air Quality Monitoring

The monitoring assessment will be done on both construction phase and operation phase
Ambient air quality will be monitored at four monitoring stations (A1, A2, A3 & A4) which
represent the ambient air quality along the site boundaries (four corners of the site). As the site
is located within the GIE, the surrounding receptors are generally industrial facilities. The air
samples collected will be analysed for Total Suspended Particulates (TSP), Particulate Matter
(PM10), sulphur dioxide (SO2) and nitrogen dioxide (NO2) which are the primary ambient air
quality pollution indicators. The results of the monitoring will be used to ascertain if the dust
suppression measures implemented for potentially dusty construction activities; and vehicle
movement are effective. The emissions will be compliant to the Environmental Quality (Clean
Air) Regulations, 1978. The monitoring exercise will also ensure regular maintenance of
construction vehicles and equipment and prevent excessive noxious exhaust emissions.

8.4) Soil and Groundwater Monitoring

The monitoring assessment will only done during operation phase. Soil and groundwater
quality monitoring is recommended to be carried out bi-annually for the lifetime of the project.
For the collection of baseline groundwater quality, seven bore wells were established at the
undeveloped site to represent groundwater quality up-gradient and down-gradient of the site.
With the establishment of the plant and associated facilities, some of these wells will need to
be abandoned to make way for the structures. Thus, the location of the monitoring wells will
need to be revised upon completion of the detailed engineering design of the plant and based
on the findings of the Radiological Impact Assessment by the Malaysian Nuclear Agency. It is
recommended that more wells be established around the Residue Storage Facility (RSF).

The groundwater samples shall be analysed for pH, total petroleum hydrocarbons, volatile
organic compounds, semi-volatile organic compounds, anions (Chloride and Sulphate) and 13
Pollutant Metals that are antimony, arsenic, beryllium, cadmium, chromium, copper, lead,
mercury, nickel, selenium, silver, thallium and zinc
 9) CONCLUSION

Name: Liew Kar Fai E16A0076

9.1 Summary of the Review

In conclusion, the EIA report was reviewed in terms of Statement of Need, Project Description
and Option, Existing Environment, Potentially Significant Impact and Mitigation Measures,
Residual Impacts, and Environmental Monitoring. Overall, the report was provided most of the
significant information and details required for the public, but some details such as expected
partnership, radioactive waste management, and details on residual impacts was not given
completely. However, the stated problem will not affecting the core concepts and information
of the report, but still it is better to include for the public to understand the big picture.

9.2 Limitations on the Report

The report has stated its limitations, where the environment consultancy of the report obtain
the required information from the public informations, government agencies, and third-party
providers. The report also stated that the consultancy has no reason to question the received
information, unless it has been explicitly noted in the report. The conclusions made are said to
be valid at the extent of the received informations are accurate and complete.
REFERENCES

Hermes, J. (2012, Jan 5). How Traffic Jams Affect Air Quality . Retrieved from Environmental
Leader: https://www.environmentalleader.com/2012/01/how-traffic-jams-affect-air-quality/

Kuan, S. H., Ghorbani, Y., & Bernard, L. H. (2016, December ). A Review of Rare Earths
Processing in Malaysia. Retrieved from Research Gate:
https://www.researchgate.net/publication/314094830_A_REVIEW_OF_RARE_EARTHS_P
ROCESSING_IN_MALAYSIA

Lynas. (2006). Lynas. Retrieved from Lynas Corporation:

https://www.lynascorp.com/Pages/Home.aspx

Gebeng Industrial Estate. (n.d.). Retrieved November 24, 2018, from

http://www.investinpahang.gov.my/index.php?ch=en_investinpahang&pg=en_industrialareas
&ac=9

OUR COMPANY. (n.d.). Retrieved November 24, 2018, from

https://www.lynascorp.com/Pages/Kuantan-Lynas-Advanced-Materials-Plant.aspx

Contributor. (2013). Malaysian Physicians for Peace and Social Responsibility.

Our Commitments & Responsibilities. (n.d.). Retrieved November 25, 2018, from
https://www.lynascorp.com/Pages/Residue-Management.aspx
APPENDICES

Fig 1: Development Map of Gebeng Industrial Estate, Retrieved from www.pknp.gov.my

Fig 2: One of the Lynas operation plant

 Fig 3: Lanthanides in powder form

Fig 4: LAMP Project Plant in GIE, Kuantan

 DISCUSSION CONDUCT
1) FIRST MEETING

Date: 16 November 2018

Attended Members: 1) Liew Kar Fai E16A0076

2) Gan Hui Kee E16A0060

3) Wong Shi Yun E16A0306

4) Chong Li Weng E16A0040

5) Wallace Lee Tian Zhu E16A0297

6) Nur Fathin Afifah bt Mah Hassan E16B0179

7) Nisrina Nadia bt Maizatul @ Maizatu E15A0139

8) Syafiqa Jauna Mohamed Jefry E15A0282

Discussed Matter:

1) Task distribution for EIA Evaluation Report

2) Setup the dates for compiling the report and recording the video

3) Discussing about the report parts and how to do an evaluation on it.

Conclusion of the Meeting:

All discussed matter have a clear conclusion done. Tasks are distributed accordingly, dates set
up for compiling is at 27/11/2018, Tuesday. And the recording of video and compile to a full
video have the date set at 27/11/2018 and 30/11/2018 respectively.
 2) SECOND MEETING

Date: 18 November 2018

Attended Members: 1) Liew Kar Fai E16A0076

2) Gan Hui Kee E16A0060

3) Wong Shi Yun E16A0306

4) Chong Li Weng E16A0040

5) Wallace Lee Tian Zhu E16A0297

6) Nur Fathin Afifah bt Mah Hassan E16B0179

7) Nisrina Nadia bt Maizatul @ Maizatu E15A0139

8) Syafiqa Jauna Mohamed Jefry E15A0282

Discussed Matter:

1) Clarification of task and update the progress of evaluation.

2) Double checking on the progress done and refine the mistakes done.

3) Drafting of the structure of evaluation plan

Conclusion of the Meeting:

The structure draft of the evaluation plan is done and the main evaluation can be started. The
tasks and questions was clarified properly, and updates will be followed time by time.
 3) THIRD MEETING

Date: 25 November 2018

Attended Members: 1) Liew Kar Fai E16A0076

2) Gan Hui Kee E16A0060

3) Wong Shi Yun E16A0306

4) Chong Li Weng E16A0040

5) Wallace Lee Tian Zhu E16A0297

6) Nur Fathin Afifah bt Mah Hassan E16B0179

7) Nisrina Nadia bt Maizatul @ Maizatu E15A0139

8) Syafiqa Jauna Mohamed Jefry E15A0282

Discussed Matter:

1) To check the evaluated parts and refine to better quality

2) Re-update the progress of evaluation plan

3) Set up the structure of the video parts

Conclusion of the Meeting:

The checking of the evaluated parts were done. And the progress is near to the conclusion part.
The structure and ways to record the video was done and ready for use at 27/11/2018 video
recording session.
 4) FOURTH MEETING

Date: 27 November 2018

Attended Members: 1) Liew Kar Fai E16A0076

2) Gan Hui Kee E16A0060

3) Wong Shi Yun E16A0306

4) Chong Li Weng E16A0040

5) Wallace Lee Tian Zhu E16A0297

6) Nur Fathin Afifah bt Mah Hassan E16B0179

7) Nisrina Nadia bt Maizatul @ Maizatu E15A0139

8) Syafiqa Jauna Mohamed Jefry E15A0282

Discussed Matter:

1) Video recording session

2) Final evaluation on the evaluation plan

3) Progressing the executive summary and compile the final report

Conclusion of the Meeting:

The video recording session was done successfully. The evaluation report will be compiled and
printed after the executive summary is done.