EIA

PRELIMINARY ENVIRONMENTAL IMPACT ASSESSMENT AND
QUANTITATIVE RISK ASSESSMENT

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

VOLUME 1: MAIN REPORT

January 2008

Prepared for

Prepared by:

ENVIRON CONSULTING SERVICES (M) SDN. BHD.
A307, PHI L EO DA MA NSARA I I , 15, J AL AN 16/ 11,
46350 PETA L I NG J AYA , SEL A NGOR, MA L A YSI A
TEL : + 60 3 7665 2986 FA X: + 60 3 7665 2987
www.environcorp.com

Contract No: MY110311A
Issue: Final Report
Project Manager
(signature):

Viji Samuel
Project Director
(signature):

Sheila Sharma
Date:
21 January 2008

This report has been prepared by ENVIRON with all reasonable skill,
care and diligence, and taking account of the manpower and resources
devoted to it by agreement with the client. This report is confidential to
the client, and ENVIRON accepts no responsibility whatsoever to third
parties to whom this report, or any part thereof, is made known, unless
formally agreed by ENVIRON beforehand. Any such party relies upon the
report at their own risk.

Preliminary Environmental Impact Assessment and
Quantitative Risk Assessment of the
Proposed Advanced Materials Plant within the
Gebeng Industrial Estate, Kuantan, Pahang, Malaysia

TABLE OF CONTENTS

RINGKASAN EKSEKUTIF

LIST OF ABBREVIATIONS

LIST OF EXHIBITS

LIST OF TABLES

LIST OF APPENDICES

LIST OF REFERENCES

1.0 INTRODUCTION.. ............................................................................................................... 1-1
1.1 PROJ ECT OVERVIEW.................................................................................................................1-1
1.2 PROJ ECT BACKGROUND............................................................................................................1-1
1.3 LEGAL REQUIREMENT ...............................................................................................................1-2
1.4 PROJ ECT PROPONENT..............................................................................................................1-3
1.5 ENVIRONMENTAL CONSULTANT..................................................................................................1-6
1.6 PROJ ECT CONCEPT ..................................................................................................................1-7
1.6.1 Lanthanides ...................................................................................................................1-7
1.6.2 Industrial Application of Lanthanides .............................................................................1-8
1.6.3 Proposed Advanced Materials Plant in Malaysia...........................................................1-9
1.7 PROJ ECT IMPLEMENTATION SCHEDULE ....................................................................................1-11
1.8 STATEMENT OF NEED .............................................................................................................1-11
1.8.1 Global Lanthanides Market Demand............................................................................1-11
1.8.2 Industrial Development in Pahang, Malaysia...............................................................1-12
1.8.3 Positive Socio-Economic Impacts to Malaysia.............................................................1-13
1.9 OBJ ECTIVES OF THE STUDY.....................................................................................................1-17
1.10 STRUCTURE OF THE REPORT ...................................................................................................1-18
1.11 LIMITATIONS OF THE REPORT...................................................................................................1-19
2.0 PROJECT DESCRIPTION......................................................................................................... 2-1
2.1 PROJ ECT LOCATION..................................................................................................................2-1
2.2 PRE-CONSTRUCTION PHASE .....................................................................................................2-1
2.3 CONSTRUCTION PHASE.............................................................................................................2-2
2.3.1 Temporary Facilities.......................................................................................................2-2
2.3.2 Land Clearing................................................................................................................2-3
2.3.3 Transportation of Building Materials and Machinery......................................................2-3
2.3.4 Infrastructure and Utility Development...........................................................................2-3
2.3.5 Construction Activities....................................................................................................2-4
2.3.6 Landscape and Revegetation........................................................................................2-5
2.4 OPERATIONAL PHASE ...............................................................................................................2-5
2.4.1 Concentration Plant (Mt Weld, Western Australia).........................................................2-5
2.4.2 Cracking and Separation Plant ......................................................................................2-6
2.4.3 List of Equipment.........................................................................................................2-11
2.4.4 List of Reagent and Annual Consumption....................................................................2-12
2.4.5 Utilities.........................................................................................................................2-15
3.0 PROJECT OPTION.. ..............................................................................................................3-1
3.1 INTRODUCTION.........................................................................................................................3-1
3.2 SITE SELECTION.......................................................................................................................3-1
3.3 GEBENG INDUSTRIAL ESTATE, KUANTAN, PAHANG, MALAYSIA......................................................3-2
3.3.1 Strategic Location in the Region....................................................................................3-3

3.3.2 Accessibility to Key Infrastructure and Available Utilities................................................3-3
3.3.3 Availability of Local Suppliers.........................................................................................3-5
3.3.4 Availability of Skilled Workforce.....................................................................................3-5
3.4 BUILD-OUT VERSUS NO-BUILD OPTIONS.......................................................................................3-6
3.4.1 Build-Out Options ..........................................................................................................3-6
3.4.2 No-Build Option.............................................................................................................3-8
3.5 RECOMMENDATION...................................................................................................................3-8
4.0 EXISTING ENVIRONMENT ....................................................................................................... 4-1
4.1 INTRODUCTION.........................................................................................................................4-1
4.2 SITE SETTING...........................................................................................................................4-2
4.2.1 Project Site....................................................................................................................4-2
4.2.2 Topography....................................................................................................................4-3
4.2.3 General Geology, Soil and Hydrogeology......................................................................4-3
4.2.4 Water Resources...........................................................................................................4-6
4.3 CLIMATE AND METEOROLOGY....................................................................................................4-7
4.3.1 Wind Speed and Direction.............................................................................................4-7
4.3.2 Temperature..................................................................................................................4-8
4.3.3 Relative Humidity...........................................................................................................4-8
4.3.4 Rainfall...........................................................................................................................4-8
4.3.5 Seismology....................................................................................................................4-9
4.4 LANDUSE WITHIN THE ZOI .........................................................................................................4-9
4.4.1 Regional Landuse Pattern.............................................................................................4-9
4.4.2 Gebeng Industrial Estate (GIE)....................................................................................4-12
4.5 HUMAN ENVIRONMENT............................................................................................................4-13
4.6 ENVIRONMENTAL BASELINE INVESTIGATION..............................................................................4-14
4.6.1 Noise Measurements...................................................................................................4-15
4.6.2 Ambient Air Quality......................................................................................................4-18
4.6.3 Wind Monitoring...........................................................................................................4-24
4.6.4 Water Quality...............................................................................................................4-26
4.6.5 Alam Sekitar Malaysia (ASMA)....................................................................................4-40
4.6.6 Riverbed Sediment Quality Monitoring.........................................................................4-44
4.6.7 Plankton.......................................................................................................................4-47
4.6.8 Macrobenthos Monitoring............................................................................................4-50
4.6.9 Soil and Groundwater..................................................................................................4-53
4.7 ECOLOGY ..............................................................................................................................4-62
4.8 SOCIO-ECONOMIC ENVIRONMENT............................................................................................4-63
4.9 PORT OF KUANTAN.................................................................................................................4-64
4.10 ROAD NETWORK ....................................................................................................................4-65
5.0 POTENTIAL ENVIRONMENTAL IMPACTS AND RECOMMENDED MITIGATION
MEASURES................................................................................................................ 5-1
5.1 INTRODUCTION.........................................................................................................................5-1
5.2 SURFACE WATER .....................................................................................................................5-2
5.2.1 Regulatory Requirements ..............................................................................................5-2
5.2.2 Construction Phase .......................................................................................................5-7
5.2.3 Operational Phase.......................................................................................................5-12
5.3 SOIL AND GROUNDWATER .......................................................................................................5-30
5.3.1 Regulatory Requirements ............................................................................................5-30
5.3.2 Construction Phase .....................................................................................................5-30
5.4 ENVIRONMENTAL NOISE..........................................................................................................5-36
5.5 SOLID WASTE ........................................................................................................................5-48

5.6 AMBIENT AIR..........................................................................................................................5-62
5.7 BIOLOGICAL RESOURCES ........................................................................................................5-88
5.7.1 Construction and Operational Phases .........................................................................5-88
5.8 SOCIO-ECONOMIC ISSUES.......................................................................................................5-90
5.9 TRAFFIC AND TRANSPORTATION ..............................................................................................5-93
6.0 ENVIRONMENTAL MANAGEMENT PLAN............................................................................... 6-1
6.1 PROJ ECT OVERVIEW.................................................................................................................6-1
6.2 EMP FORMAT ..........................................................................................................................6-1
6.3 GUIDELINES FOR THE CONSTRUCTION PHASE EMP ....................................................................6-2
6.4 GUIDELINES FOR THE OPERATIONAL PHASE EMP .......................................................................6-3
6.5 ENVIRONMENTAL MONITORING AND AUDITING.............................................................................6-4
6.5.1 Baseline Data................................................................................................................6-5
6.5.2 Water Quality Monitoring...............................................................................................6-5
6.5.3 Boundary Noise Monitoring............................................................................................6-7
6.6 AIR QUALITY MONITORING ........................................................................................................6-8
6.6.2 Operational Phase.........................................................................................................6-8
6.6.3 Soil and Groundwater Monitoring...................................................................................6-9
6.7 ENVIRONMENTAL COMPLIANCE AUDITING .................................................................................6-10
7.0 EMERGENCY RESPONSE PLAN............................................................................................. 7-1
7.1 INTRODUCTION.........................................................................................................................7-1
7.2 OBJ ECTIVES.............................................................................................................................7-1
7.3 BASIS OF EMERGENCY RESPONSE PLAN (ERP).........................................................................7-2
7.4 EMERGENCY RESPONSE PLAN (ERP)........................................................................................7-3
7.4.1 Organisation..................................................................................................................7-3
7.5 LOCAL RESPONSE TEAMS .........................................................................................................7-3
7.6 TYPES OF EMERGENCY .............................................................................................................7-4
7.6.1 Emergency Classification Levels ...................................................................................7-5
7.6.2 General Responsibilities of On Scene Commander (OSC) and Emergency Response
Teams......................................................................................................................................7-5
7.6.3 Emergency Equipment and Materials ............................................................................7-8
7.7 EMERGENCY RESPONSE FLOW CHART AND RESPONSE PROCEDURES FOR ON-SITE
EMERGENCIES ......................................................................................................................................7-9
8.0 SUMMARY AND CONCLUSION ............................................................................................... 8-1
8.1 INTRODUCTION.........................................................................................................................8-1
8.2 WATER QUALITY.......................................................................................................................8-1
8.3 SOIL AND GROUNDWATER .........................................................................................................8-5
8.4 NOISE......................................................................................................................................8-8
8.5 WASTE ..................................................................................................................................8-12

8.6 AMBIENT AIR..........................................................................................................................8-15
8.7 BIOLOGICAL RESOURCES ........................................................................................................8-19
8.7.1 Construction & Operational Phases.............................................................................8-19
8.8 SOCIO-ECONOMIC IMPACTS ....................................................................................................8-21
8.9 CONCLUSION..........................................................................................................................8-21


LIST OF ABBREVIATIONS
2020 Nations Vision 2020
AELB Atomic Energy Licensing Board
Ag Silver
AMP Advanced Materials Plant
AN Ammoniacal Nitrogen
APHA American Public Health Association
As Arsenic
ASMA Alam Sekitar Malaysia
Ba Barium
BOD Biochemical Oxygen Demand
bgs below ground surface
Ca Calcium
C1
2
Free Chlorine
Cd Cadmium
Ce Cerium
CN Cyanide
CO Carbon Monoxide
CO
3
Carbonate
COD Chemical Oxygen Demand
Cr
3+
Chromium Trivalent
Cr
6+
Chromium Hexavalent
Cu Copper
dB desibel
DIVs Dutch Intervention Values
DO Dissolved Oxygen
DOE Department of Environment
DSM Department of Standards
Dy Dysprosium
EAGC East Asian Growth Corridor
ECID East Coast Industrial Development
EDTA Ethylenediaminetetraacetric Acid

EIA Environmental Impact Assessment
EMP Environmental Management Plan
Er Erbium
ERP Emergency Response Plan
ESC Erosion and Sedimentation Control Plan
Eu Europium
FGD Flue Gas Desulphurisation Residue
FOB Fine Ore Bin
FGD Flue Gas Desulphurisation
Gd Gadolinium
GIE Gebeng Industrial Estate
H
2
SO
4
Sulfuric Acid
HF Hydrogen Fluoride
Hg Mercury
HDS High Density Sludge
HIC High Intensity Conditioner
Ho Holmium
Hz Hertz
INWQS Interim National Water Quality Standards
IOM Iron Oxide Material
La Lanthanum
Ln Lanthanide
LnO Lanthanide Oxide
LOR Level of Reporting
Lu Lutetium
Lynas Corp Lynas Corporation Ltd
Lynas Lynas Malaysia Sdn Bhd
Mg Magnesium
MM Modified Mercalli
MMS Malaysian Meteorological Services
Mn Manganese
MNA Malaysian Nuclear Agency
MPK Majlis Perbadnaran Kuantan / Kuantan Municipal Council

MSL Mean Sea Level
MVROM Ministry Van Volkshuisvesting Ruimtelijke Ordening en Milieubeheer
(Dutch Ministry of Housing, Spatial Planning and the Environment)
Nd Neodynium
Ni Nickel
NO
2
Nitrogen Dioxide
NSRs Nearest Sensitive Receivers
NUF Neutralisation Underflow Solids from the wastewater treatment
process
O
3
Ozone
OSA On-Stream Analyser
O&G Oil & Grease
PAHs Polycyclic Aromatic Hydrocarbons
PASDEC Pahang State Development Corporation
Pb Lead (Plumbum)
PETRONAS Petroleum National Berhad
pH log [H
+
]
PID Photo-ionizing Detector
PM
10
Particulate Matter
Pm Promethium
Pr Praseodynium
QRA Quantitative Risk Assessment
ROM Run-of-Mine
RMAQG Recommended Malaysian Air Quality Guidelines
S
2
Sulphide
SAS Sultan Ahmad Shah
SEDC State Economic Development Corporation
SEG Samarium, Europium, Gadolinium
SiF
4
Silicon Tetra Fluoride
Sm Samarium
Sn Tin
SMIs Small and Medium size Industries
SO
2
Sulfur Dioxide

SO
3
Sulfur Trioxide
SPT The Standard Penetration Tests
STPs Sewage Treatment Plants
Surau Mosque
SVOCs Semi- Volatile Organic Compounds
SWL Static Water Level
Tb Terbium
TCM tetrachloromercurate
TLDM Tentera Laut DiRaja Malaysia / Royal Malaysian Navy
Tm Thulium
TNB Tenaga Nasional Berhad
tpa tonnes per annum
TPH Total Petroleum Hydrocarbons
TSF Tailings Storage Facility
TSP Total Suspended Particulates
TSS Total Suspended Solids
UMP Universiti Malaysia Pahang
USCS Unified Soil Classification System
VOCs Volatile Organic Compounds
WHO Worth Health Organization
WLN Water Leach Neutralization Residue
WLP Water Leach Purification
VAT Value Added Tax
Y Yttrium
Yb Ytterbium
ZOI Zone of Impact
Zn Zinc

LIST OF EXHIBITS

Exhibit 1.1: Regional Location of the Advanced Materials Plant
Exhibit 1.2 Satellite Imagery of the Advanced Materials Plant
Exhibit 1.3: Periodic Table
Exhibit 1.4: Industrial Applications of Lanthanide Elements
Exhibit 1.5: Project Implementation Schedule

Exhibit 2.1: Site Layout
Exhibit 2.2: Overall Process Block Flow Diagram
Exhibit 2.3: Block Flow Diagram: Concentration and Cracking & Separation

Exhibit 4.1a: Zone of Impact (5 km radius of the Project Site)
Exhibit 4.1b: Peta Cadangan Blok Perancangan Sungai Karang, 2015
Exhibit 4.2: Location of the Gebeng Industrial Estate
Exhibit 4.3: Site Layout Plan
Exhibit 4.4: Photolog Describing the Project Site
Exhibit 4.5: Topographical Survey at Gebeng Industrial Estate, Kuantan
Exhibit 4.6: Geological Formations at the Site
Exhibit 4.7: Drainage at Gebeng Industrial Estate
Exhibit 4.8: Photolog Describing Sungai Balok
Exhibit 4.9: Annual Wind Rose Summary for the MMS Monitoring Station at the Sultan
Ahmad Shah Airport, Kuantan, Pahang (1975-2006)
Exhibit 4.10: Seasonal Wind Rose Summary for the MMS Monitoring Station at the Sultan
Ahmad Shah Airport, Kuantan, Pahang (1975-2006)
Exhibit 4.11: Temperature & Relative Humidity Data for the MMS Monitoring Station at
the Sultan Ahmad Shah Airport, Kuantan, Pahang (Jan 1968- Oct 2007)
Exhibit 4.12: Rainfall Data Summary for the MMS Monitoring Station at Sultan Ahmad
Shah Airport, Kuantan, Pahang (Jan 1951- Oct 2007)
Exhibit 4.13: Photolog of the Surrounding Industrial Area
Exhibit 4.14: Location of Environmental Monitoring Stations
Exhibit 4.15: Noise Profiles at the Site (Stations N1 N4)

Exhibit 4.16: ASMA Water Quality Monitoring Stations
Exhibit 4.17: Soil and Groundwater Sampling Locations
Exhibit 4.18: Layout of the Port of Kuantan
Exhibit 4.19: Road Network

Exhibit 5.2.1: Earthwork Layout
Exhibit 5.2.2: Earthwork Site Trap Details
Exhibit 5.2.3: Earthwork Wash Trough Details
Exhibit 5.2.4: Block Flow Diagram of the Wastewater Treatment Process
Exhibit 5.4.1: Normal Night-Time Operation LAeq(9 hour) Noise Level Contours Close to
Plant
Exhibit 5.4.2: Normal Night-Time Operation LAeq Noise Level Contours Close to
Surrounding Areas
Exhibit 5.5.1: Residue Storage Facility Design
Exhibit 5.5.2: NUF Cross Section A
Exhibit 5.5.3: FGD Cross Section B
Exhibit 5.5.4: WLP Cross Section C
Exhibit 5.6.1: Waste Gas Treatment System (1)
Exhibit 5.6.2: Waste Gas Treatment System (2)
Exhibit 5.6.3: 2005 Annual Windrose, Malaysia
Exhibit 5.6.4: Maximum Predicted 1 Hour SO
2
GLCs (ug/m3) (Normal Operations 4 kilns)
Exhibit 5.6.5: Maximum Predicted Annual HF GLCs (ug/m3) (Normal Operations 4 kilns)
2
GLCs (ug/m3) (Emergency Operations 2
scrubbers)
2
scrubbers)
2
scrubbers)
Exhibit 5.6.9: Maximum Predicted 15-minute H
2
SO
4
GLCs (ug/m3) (Emergency Operations
4 scrubbers)
Exhibit 5.6.10:Maximum Predicted 1 Hour H
2
SO
4
scrubber)

Exhibit 5.6.11: Maximum Predicted 1 Hour H
2
SO
4
scrubbers)
Exhibit 5.6.12:Maximum Predicted 1 Hour H
2
SO
4
GLCs (ug/m3) (Emergency Operations
4 scrubbers)
Exhibit 5.6.13:Frequency of 1 Hour H
2
SO
4
AAQG Exeedence (Emergency Operations 1
scrubber)
2
SO
4
Exeedence (Emergency Operations 2
scrubbers)
2
SO
4
AAQG Exeedence (Emergency Operations 4
scrubbers)

Exhibit 7.1: Flow Chart for On-Site Fire Emergency
Exhibit 7.2: Line of Communication within the Emergency Response Team


LIST OF TABLES

Table 1.1 EIA Study Team
Table 1.2 Lanthanides Elements
Table 1.3 Applications of Lanthanides

Table 2.1 List of Major Equipment within the Advanced Materials Plant
Table 2.2 Annual Reagent Consumption for the Cracking & Separation Plant

Table 4.1 Summary of Current Land Uses within the Zone of Impact (ZOI)
Table 4.2 Development Stages of the Gebeng Industrial Estate (GIE)
Table 4.3 Noise Monitoring Stations
Table 4.4 Summary of Noise Levels (LAeq (dBA))
Table 4.5 Maximum Permissible Sound Level (L
Aeq
) by Receiving Landuse for Planning
and New Development
Table 4.6 Noise Sources at the Noise Monitoring Stations
Table 4.7 Air Monitoring Stations
Table 4.8 Ambient Air Quality Monitoring Results
Table 4.9 Ambient Air Quality Criteria
Table 4.10 Wind Monitoring Stations
Table 4.11 Summary of Percentage Frequency of Various Direction & Speed
Table 4.12 Summary of Wind Direction & Speed
Table 4.13 Water Quality Monitoring Stations
Table 4.14 Method of Chemical Analysis
Table 4.15 Water Quality Results (W1, W2, W3, W4, W5, W6 & W7) (High Tide)
Table 4.16 Water Quality Results (W1, W2, W3, W4, W5, W6 & W7) (Low Tide)
Table 4.17: Secondary Water Quality Data from Sungai Balok & Sungai Tunggak
Table 4.18 Riverbed Sediment Monitoring Sations
Table 4.19 Method of Chemical Analysis
Table 4.20 Results of Chemical Analysis
Table 4.21 Plankton & Macrobenthos Monitoring Stations

Table 4.22 Results of Plankton Recorded at Monitoring Stations
Table 4.23 Results of Macrobenthos Recorded at Monitoring Stations
Table 4.24: Groundwater Elevation Data
Table 4.25 Summary of Detected Constituents in Soil
Table 4.26 Summary of Detected Constituents in Groundwater

Table 5.2.1: Standard A and B Effluent Discharge Limits
Table 5.2.2: National Interim Water Quality Standards for Inland Waters
Table 5.2.3: Water Depth and Channel Width at Survey Sites
Table 5.2.4: Flows of Sg. Balok
Table 5.2.5: Tidal levels at the Sg. Balok Estuary (Tidal Station at Tanjung Gelang)
Table 5.2.6: WWTP Treated Effluent Quality
Table 5.2.7: Summary of Event Mean Concentrations (EMC)
Table 5.2.8: Typical Event Mean Concentration Values from MSMA
Table 5.2.9: Normal Operation with No Rainfall
Table 5.2.10: Normal Operation in Low Rainfall Period
Table 5.2.11: Normal Operation with 5 Year ARI Rainfall
Table 5.2.12: Releasing of Untreated Effluent with No Rainfall (Worst Case Scenario)
Table 5.2.13: Release of Untreated Effluent in Low Rainfall Period
Table 5.2.14: Release of Untreated Effluent with 5 Year ARI Rainfall
Table 5.4.1: Schedule 6: Maximum Permissible Sound Levels (Percentile Ln and Lmax) of
Construction, Maintenance and Demolition Work by Receiving Land Use
Table 5.4.2: Schedule 1: Maximum Permissible Sound Level by Receiving Land Use for
Planning and New Development
Table 5.4.3: Noise Levels for Typical Equipment Used for Construction
Table 5.4.4: Noise Levels for Typical Equipment Used During Piling Activities
Table 5.4.5: Transmission Loss Values Used in Modelling, dBA
Table 5.4.6: Source Sound Power Levels, dB
Table 5.5.1: Residue Streams Summary
Table 5.5.2: Major Waste Composition of the Residue Streams and Sludge from the
WWTP
Table 5.5.3: Summary of Potential Residue End Uses

Table 5.6.1 Proposed Advanced Materials Summary of Operational Modes
Table 5.6.2 Ambient Air Quality Guidelines
Table 5.6.3 Short-Term Exposure Levels
Table 5.6.4 Emissions Standards for Stationary Sources
Table 5.6.5 Emissions Information and Stack Release Parameters Normal and
Emergency Operations
Table 5.6.6: Proposed Advanced Materials Plant Summary of Operational Modes
Table 5.6.7: Emissions Information and Stack Release Parameters Normal and
Emergency Operations
Table 5.6.8: Maximum Predicted Ground Level Concentrations for Normal Operations
Table 5.6.9: Maximum Predicted Ground Level Concentrations for Emergency Operations
Table 5.6.10: Summary of Probability of an Exceedence Event Occurring

LIST OF APPENDICES

Appendix 1 Correspondences

Appendix 2 a. Certificate of Analyses: Ambient Air Quality, River Water
Quality & Boundary Noise Data
b. Certificate of Analyses: Soil & Groundwater

Appendix 3 a. Lynas Advanced Materials Project: Conceptual Design for Residue
Storage Facility Gebeng
b. Lynas Advanced Materials Project: Preliminary Comparison of
Residue Disposal Options
c. Lynas Advanced Materials Project: Study on Potential Dioxin & Furan
Emissions

Appendix 4 Traffic Impact Assessment

LIST OF REFERENCES

Department of Environment (DoE) (1989). Recommended Malaysian Air Quality Guidelines.
Department of Environment, Malaysia.

Department of Environment (DoE) (1978). Environmental Quality (Clean Air) Regulations
1978. Department of Environment, Malaysia.
`
Fischer HB, List EJ, Koh RCY, Imberger J and Brooks NH. Mixing in Inland and Coastal
Waters. Academic Press 1979.

Office of Environmental Health (OEH) (1999). 1999 Update Arizona Ambient Air Quality
Guidelines. Report prepared for the Arizona Department of Environmental Quality, May
1999.

Users Manual CORMIX: a Hydrodynamic Mixing Zone Model and Decision Support
System for Pollutant Discharges into Surface Waters. US Environmental Protection Agency,
1996.

World Health Organisation (WHO) (2000). Guidelines for Air Quality. World Health
Organisation.


1-1

CHAPTER ONE
1.0 INTRODUCTION

1.1 PROJECT OVERVIEW

Lynas Malaysia Sdn. Bhd. (Lynas), a wholly owned subsidiary of Lynas Corporation
Limited (Australia) intends to construct and operate an Advanced Materials Plant on
privately-owned industrial land located within the Gebeng Industrial Estate (GIE),
Kuantan, Pahang. The proposed site is currently vacant and has an area of 100 ha.

The plant will process up to 80,000 tonnes per annum (tpa) wet weight basis of
lanthanide concentrate (equivalent to 65,000 tpa dry weight basis) and produce 22,500
tpa (LnO or lanthanide oxide basis) of high purity lanthanide compounds in the form
of a suite of six (6) different products. These products will be exported directly to the
companys global customers based in the US, Japan, Europe and China.

Lynas Corporation Limited operates an open pit mine on a rich lanthanide deposit at
Mt. Weld, Western Australia. At the mine site, the lanthanide ore will be extracted,
crushed and concentrated to produce the lanthanide concentrate which is the primary
raw material for the proposed plant. The concentrate will be transported from Mt.
Weld by road and rail to Port for shipment via sea containers to Port of Kuantan in
Pahang. The containers will be transported from the Kuantan Port by road to the
project site within the GIE.

The regional location of the proposed plant site and a satellite image showing the site
and its immediate surrounding areas are presented in Exhibits 1.1 and 1.2.

1.2 PROJECT BACKGROUND

Upon undertaking a project feasibility exercise in 2005-2006, Lynas Corporation
Limited identified Malaysia as a viable location for the siting of their proposed
Advanced Materials Plant based on economic and infrastructure considerations.
Pursuant to this, discussions were held with the Malaysian Industrial Development
Authority (MIDA) and other regulatory agencies and a 203 ha plot was identified
within the Teluk Kalong Industrial Area (TKIA) in Kemaman, Terengganu as a
suitable location for the establishment of the plant. With the intention of investing and
operating the plant in Malaysia, the company incorporated its Malaysian subsidiary,
Lynas, in November 2006. As required by the Department of Environment, Ministry
of Natural Resources and Environment, the Preliminary EIA and QRA reports for the
plant operations at this site were prepared and submitted to the department in May
2007. Approval from the department was obtained in July 2007. Lynas also obtained
approval from the Atomic Energy Licensing Board (AELB) for the Class A Milling
License (Siting and Construction Phases) in August 2007.

1-2

In late August 2007, Lynas received advice from MIDA stating that that the
Malaysian Government would like to seek the companys consideration in relocating
the plant to an alternative location. Given the nature of the operations, the presence of
dedicated industrial estates for the chemical and petrochemical industries and the
required supporting facilities and infrastructure, Lynas was requested to consider
relocating the proposed plant within the State of Pahang. This request was made
following high level consultations between the Federal Government and the State of
Terengganu.

Realising the many benefits of siting the plant within the State of Pahang, the
company decided to relocate the plant to the GIE in Kuantan, Pahang.

This Preliminary Environmental Impact Assessment (EIA) and Quantitative Risk
Assessment (QRA) address the environmental impacts and risks arising from the
establishment of the plant within the GIE.

1.3 LEGAL REQUIREMENT

In the promotion of environmentally sustainable development, the Government of
Malaysia has established the necessary legal and institutional requirements to ensure
that environmental factors are deliberated during the early stages of project planning.

Section 34A of the Environmental Quality Act 1974 (and its Amendments) requires
any person intending to carry out a prescribed activity to submit a report on the
impact on the environment to the Director General of the Department of
Environmental (DOE) for examination. The Environmental Quality (Prescribed
Activities) (Environmental Impact Assessment) Order 1987 lists 19 Prescribed
Activities that warrant the submission of an EIA to the Director General of the
Environment for approval.

The proposed activity falls under Prescribed Activity 11 (b): Ore processing,
including concentrating for aluminium, copper, gold or tantalum of the Regulations.
Therefore, the submission of a preliminary EIA to the Department of Environment
(DOE) Pahang for approval prior to project commencement is a legal requirement.

This preliminary EIA report has been prepared in accordance to the following
guidelines published by DOE:

The Handbook of Environmental Impact Assessment Guidelines (1995)
Environmental Impact Assessment Guidelines for Industrial Projects (1994)

1-3

As required under the Guidelines for Industrial Projects published by DOE, a QRA
has been undertaken for the proposed plant based on the requirements of the
Environmental Impact Assessment Guidelines for Risk Assessment (2004) published
by the DOE.

The lanthanide concentrate exhibits a low level of naturally occurring radiation is
classified as a radioactive substance under the Atomic Energy Licensing Act, 1984
and therefore the operation of the plant requires a Class A Milling License from the
AELB in accordance to the requirements of the Act. Since Lynas is in possession of
the Class A Milling Licence (Siting and Construction Phase) for the original site in
Teluk Kalong, Terengganu, the AELB has advised Lynas to submit information
pertaining to the new site for evaluation and approval. The application was lodged on
the 18
th
of January 2008. The Radiological Consultant for the project is the Malaysian
Nuclear Agency (Nuclear Malaysia).

1.4 PROJECT PROPONENT

The Project Proponent is Lynas, a wholly owned subsidiary of Lynas Corporation
Limited which is an Australian company headquartered in Sydney, New South Wales.
The company is listed on the Australian Stock Exchange and the Singapore Stock
Exchange, and has over 20 years of experience in the mining industry and 6 years of
experience in the lanthanides industry. The major shareholders of the company are
Ospraie Management, Goldman Sachs, JP Morgan and RAB Capital.

The company currently owns one of the few commercially viable lanthanides deposit
outside of China, at Mount Weld in Western Australia which is the richest lanthanide
oxide deposit globally.

1-4
Lynas Transales
Pty Ltd
(Dormant)
ABN 31 103 936 232
Lynas
Corporation
Limited
ACN 009 066 648
ABN 27 009 066 648
Mt Weld
Niobium Pty
Ltd
(Dormant)
ACN 118 216 014
Mt Weld Rare
Earths
Pty Ltd
(Dormant)
ABN 73 053 160 302
Mt Weld
Mining Pty Ltd
ABN 96 053 160 400

Mining operations
company at Mt Weld
Lynas
Malaysia Sdn
Bhd
Malaysian Co. Number
752289 D
Mt Weld
Holdings
Limited
(Dormant
holding company only)
ABN 75 073 998 106

The current corporate structure of the Lynas Group is illustrated below:


1-5

All enquires pertaining to the company, the proposed Advanced Materials Plant in
Malaysia and the mining and concentration operations at Mt. Weld, Western Australia
are to be directed to:

Malaysia

Lynas Malaysia Sdn. Bhd.
PT6869, Pusat Perniagaan Bukit Kuang 2
Bukit Kuang, Kemaman
24000 Terengganu
Malaysia

Telephone: +60 9 8584445
Facsimile: +60 9 8584449

Contact Person:
Mr. Michael Chan Tan Nean
Senior Manager

Australia

Lynas Corporation Ltd
Level 7, 56 Pitt Street
Sydney NSW 2000
Australia

Telephone: +61 2 8259 7100
Facsimile: +61 2 8259 7199

Contact Persons:
Mr. Michael J. Vaisey
Director, Lynas Malaysia Sdn. Bhd.
Vice President (Technical Development), Lynas Corporation Ltd

Mr Michael Wolley
Director, Lynas Malaysia Sdn. Bhd.
Vice President (Operations), Lynas Corporation Ltd

Mr. Nicholas Curtis
Chairman, Lynas Malaysia Sdn. Bhd.,
Executive Chairman, Lynas Corporation Ltd,

1-6

1.5 ENVIRONMENTAL CONSULTANT

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. ENVIRON is registered with the Department of Environment
(DOE) Malaysia as an EIA Consulting Firm.

ENVIRON Consulting Services (M) Sdn Bhd is a wholly owned subsidiary of
Environ International Incorporation established in the US. As an international
technical and scientific consultancy, ENVIRON provides state-of-the-art scientific,
engineering, and strategic risk management assistance to clients worldwide including
national and multinational industrial and commercial concerns, law firms, developers
and property managers, trade associations, lending institutions, insurance
professionals, and public sector agencies. The firm has regional offices throughout the
US, UK, Europe, and Asia Pacific staffed by professionals with experience and
expertise in a wide variety of disciplines, including engineering, geosciences,
environmental sciences, life sciences, public health, and regulatory affairs.

Table 1.1 lists the team members and their respective roles and responsibilities in
successfully completing this study. The key team members are registered with the
DOE as EIA Consultants (Individual Category).

All questions pertaining to this study can be directed to:

ENVIRON Consulting Services (M) Sdn Bhd
A307, Phileo Damansara 2,
15, Jalan 16/11,
Off Jalan Damansara,
46350 Petaling Jaya, Selangor Darul Ehsan.

Telephone: +60 3 7665 2986
Facsimile: +60 3 7665 2987

Contact Persons:
Ms. Viji Samuel/Ms. Sheila Sharma


1-7

Table 1.1: EIA Study Team

Name Designation/Responsibility
Sheila Sharma
(DOE Registration No: C0366)
Project Director/ Technical Direction and Overview,
Overall Environmental Management, Ecology, Impact
Assessment and Mitigation Measures.

Viji Samuel
(DOE Registration No: C0105)
Project Manager/ Preparation of EIA Report, Water
Quality Solid & Scheduled Waste, Socio-Economy,
Traffic & Transportation, Aquatic Biology and
Environmental Management.

Nicholas Ng Tuan Hooi
(DOE Registration No: AS0131)
Project Engineer/ Geology, Hydrogeology, Soil and
Groundwater and Waste Management.

Gaya Indran
(DOE Registration No: AC0077)
Project Assistant/ Assisting in preparation of EIA
Report, Hydrogeology, Water Quality, Scheduled Waste,
Environmental Management.

Taufik Rashidi
(DOE Registration No: AC0368)
Site Engineer/Supervision of Baseline Environmental
Monitoring Programme & ACAD Support

Brian Bell, Ruth Rogan Air Quality Modelling Specialist

Ian Mockett
HR Wallingford (M) Sdn. Bhd.

Water Quality Modelling Specialist

Daniel Lloyd
Lloyds Acoustics Ptd. Ltd. (Australia)

Noise Modelling Specialist

Henk Hersft
Det Norske Veritas

Quantitative Risk Assessment
Environmental Science (M) Sdn Bhd Environmental Monitoring and Laboratory Analysis

ALS Technichem (M) Sdn. Bhd. Environmental Monitoring and Laboratory Analysis

1.6 PROJECT CONCEPT

1.6.1 Lanthanides

Lanthanides are a group of chemical elements comprising 15 metallic elements
known as the Lanthanide Series. These elements are represented by the single square
of Lanthanum in the main part of the periodic table, and listed in a separate sub group
to the main groupings as shown in the Periodic Table presented in Exhibit 1.3.

The elements within the Lanthanide Series are named in Table 1.2 below.

1-8

Table 1.2: Lanthanides Elements

Lanthanides Element

Ce Dy Er Eu Gd Ho La Lu
Cerium Dysprosium Erbium Europium Gadolinium Holmium Lanthanum Lutetium

Nd Pr Pm Sm Tb Tm Y Yb
Neodymium Praseodymium Promethium Samarium Terbium Thulium Yttrium Ytterbium

Lanthanides are not found as individual free metals in the earths crust, rather within a
mix of the elements in various mineral forms that need to be separated for their
individual or combined commercial use. The Mt Weld deposit in Western Australia
is the richest known lanthanide deposit globally.

1.6.2 Industrial Application of Lanthanides

Lanthanides have unique properties which make them indispensable for many
technological applications. These elements play a critical role in several sectors
including the electronics, automotive, environmental protection and petrochemical
industries. In particular, the automotive industry is of great importance, with
lanthanides playing a key role in the operation of hybrid vehicles.

As these industries grow and as global research continues to develop new applications
for lanthanides, demand for these elements as well as their products is expected to
increase. Some of the main applications of lanthanides are listed in Table 1.3 below.

Table 1.3: Industrial Application of Lanthanides

Application Examples of Application Benefits

Environmental
Applications

Catalytic converters
Hybrid vehicles
Water treatment
Lead replacement in paints

Greenhouse Gas Reduction

Digital Technology

Lanthanide magnets
Flat panel displays
Ceramic capacitors

Enabling miniaturisation

Energy Conservation &
Colour and Lights

Compact fluorescent lights
NiMH batteries
Fuel cells
Phosphors for flat screen
displays/monitors using CRT, LCD and
PDA technologies
Polishing powders

Energy saving


1-9

An illustration of the various lanthanide applications is presented in Exhibit 1.4.

1.6.3 Proposed Advanced Materials Plant in Malaysia

Lynas intends to construct and operate the Advanced Materials Plant within the
Gebeng Industrial Estate (GIE) in Kuantan, Pahang, Malaysia. The lanthanide
concentrate which is the primary raw material for the plant will be obtained from the
Mt. Weld mine operations located near Laverton in Western Australia. The lanthanide
deposit at Mt Weld was discovered more than 20 years ago and over the years some
AUD 25 million has been spent for the improvement of its resource quality. The
deposit is based on a concentration of lanthanide elements within a residual weathered
horizon which overlies the 3 km-diameter carbonatite intrusive.

The proposed Advanced Materials Plant in Malaysia will process the lanthanide
concentrate (raw material) 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.

At Mt. Weld, the lanthanide ore will be extracted via open pit mines, stockpiled and
crushed onsite to a particle size of 40mm. These aggregates will then be conveyed to a
concentrator plant located within the mine site. The resultant product of the
concentration process is the lanthanide concentrate and will be transported to Port,
some 1000 km south of Mt. Weld for shipping to Port of Kuantan, Pahang, Malaysia.

From the Port of Kuantan, the concentrate will be transported to the proposed plant
site within the GIE which lies about 3 km northwest of the port.

In its natural form, the mined lanthanide ore has low level of radioactivity measuring
approximately 30.6 Bq/g. The thorium and uranium contents of the ore are 750 ppm
(as ThO
2
) and 28 ppm (as U
3
O
8
) by weight respectively. After the concentration
process, the radioactivity of the lanthanide concentrate is estimated at 61.0 Bq/g with
thorium and uranium contents of 1600 ppm (as ThO
2
) and 29 ppm (as U
3
O
8
) by
weight respectively.

At the Advanced Materials Plant within the GIE, the imported lanthanide concentrate
will undergo two main stages of processing, i.e. (1) cracking and separation and (2)
product finishing. In the first stage, the concentrate will be roasted with sulphuric acid
in rotary kilns at high temperatures and atmospheric pressure and, water leached to
produce a lanthanide sulphate solution. This solution will then be subjected to a series
of solvent extraction systems for the extraction of the lanthanide elements in solution.
The solution will then be further separated and purified into the final products
(individual lanthanide elements or mixed lanthanide elements) in the product finishing
stage.

1-10

The Advanced Materials Plant will be designed for a lanthanide production capacity
totalling some 22,500 tpa (LnO or lanthanide oxide basis), distributed over a range of
high purity products.

The mix of products can be varied within a range according to market demand, and
design capacities for individual lanthanide products are as follows (volumes are LnO
equivalent):

SEG/HRE Carbonate 1,160 tpa
LCPN Carbonate 5,400 tpa
Lanthanum Chloride, Carbonate or Oxide 2,800 tpa
Lanthanum-Cerium Carbonate 8,200 tpa
Cerium Chloride, Carbonate or Oxide 5,400 tpa
Dydimium Oxide 5,600 tpa
Neodymium Oxide 2,000 tpa
Praseodymium Oxide 800 tpa

SEG-HRE carbonate is a product containing Samarium, Europium, Gadolinium
(SEG) and Heavy Rare Earths (HRE) such as Terbium, Dysprosium and Yttrium, in a
carbonate form. The customers for this product are the processors that produce
phosphors for colour screens and energy efficient lighting such as compact
fluorescent lights.

LCPN Carbonate contains Lanthanum, Cerium, Praseodymium and Neodymium and
will be sold to downstream processing plants for separation into individual lanthanide
products.

Lanthanum Chloride, Carbonate or Oxide will be produced according to customer
requirements, for use in the manufacture of Fluid Cracking Catalysis (used in oil
refining) and to the manufacturers of battery alloy for nickel metal hydride (NiMH)
rechargeable batteries. There is potential for downstream processing to battery alloy
with the addition of a metal production plant. High purity Lanthanum Oxide is used
for optical lens glass. Lanthanum chloride is used for chemical catalysts and for
water treatment.

Lanthanum-Cerium Carbonate will be sold directly to the manufacturers of glass
polishing powder for the plasma TV and LCD TV industries.

Cerium Chloride, Carbonate or Oxide will be produced and sold directly to
manufacturers of automotive catalysts powders for the automotive industry.

Didymium Oxide (Praseodymium and Neodymium combined) and Neodymium
Oxide will be sold to manufacturers of magnetic alloys, and there is potential to go
further downstream with the addition of a metal production plant.

1-11

Praseodymium Oxide will be sold to manufacturers of pigments for the colourisation
of ceramic tiles and plastics.

The radioactivity levels of these products will be very low as the radioactive
components present in the ore (uranium and thorium) will be retained in the solid
waste streams generated from the processes within the plant.

The finished products from the plant will be packaged and transported to the Port of
Kuantan for shipment via containers to the companys global customers.

1.7 PROJECT IMPLEMENTATION SCHEDULE

Preliminary earthworks for the development of infrastructure will commence in mid-
January 2008. Approval for these activities has been issued by the Department of
Environment, Pahang via written correspondence dated 4
th
December 2007 (a copy of
the letter is attached in Appendix 1 of this section), subject to compliance of a set of
approval conditions.

Plant construction activities are scheduled to commence in March 2008 followed by
the equipment commissioning activities. Completion of the construction phase is
expected to be in June 2009 at which time plant operations will commence. The civil
and structural works, equipment installation, dry commissioning and wet
commissioning of the various plant components will be undertaken concurrently in
stages to achieve this target.

The detailed project implementation schedule is presented in Exhibit 1.5.

1.8 STATEMENT OF NEED

1.8.1 Global Lanthanides Market Demand

Global demand for lanthanides was 95,000 metric tons lanthanide oxide equivalents in
2005 and is expected to grow annually by 10% to over 154,000 metric tons by 2010.

The lanthanides applications are expected to grow in line with its increased usage in
permanent magnets, consumer electronics and automotive catalytic converters. In
particular, demand growth will be seen in the automotive industry as more electric
components replace hydraulic systems and more NiMH rechargeable batteries are
used in hybrid vehicles.

1-12

The expanding lanthanides market will require higher purity mixed and separated
lanthanide products to meet the growing demand for the elements in demand.
Therefore, strong demand is expected for cerium in automotive catalysts, lanthanum
in NiMH batteries and those elements used in Neo magnets (Neodymium,
Praseodymium, Dysprosium, and Terbium).

Global supply of lanthanides has experienced significant changes in the past decade.
China currently supplies approximately 95% of the global lanthanides market with
more than 70% of the supply of light lanthanides originating from one mine in China.
With this, global lanthanides processors have relocated their production plants to
China resulting in China becoming the dominant supplier of the lanthanide oxides
(with over 90% of the total supply capacity) as well as the dominant processor and
user of refined lanthanide compounds.

However, with the recent implementation of more stringent regulatory controls
imposed by the government, the quantity of lanthanides extracted from China is
expected to decrease. Exploitation of alternative sources is now necessary to cater for
the high demand for the lanthanide elements and to ensure a steady and adequate
supply for the global processors.

Mt Weld in Western Australia has a very high grade deposit containing light
lanthanides and Europium, a heavy lanthanide element and is currently the only
commercially viable resource of significant size outside of China. The lanthanide
deposit at Mt. Weld in Western Australia which has significant commercial value is
now deemed an important alternative source for lanthanide elements. The deposit is
currently the worlds richest lanthanide oxide body, capable of supplying up to 20%
of the global market for over 30 years.

The proposal by Lynas to commercially mine the lanthanide deposit and process it
into the various elements is therefore timely and justified.

1.8.2 Industrial Development in Pahang, Malaysia

Industrial development is one the core economic sectors of the State of Pahang.
Realising the importance of this sector, the State Government has established the
necessary mechanisms to promote and support industrial development, specifically
heavy industries, iron and steel industries, oil and gas and the chemical &
petrochemical sectors. The GIE which comprises predominantly of these industries
significantly contributes to the economy of the Pahang State as a whole
1
.

1
Kuantan Structure Plan for 2015, Kuantan Municipal Council

1-13

Gebeng falls within the East Coast Industrial Development (ECID) Corridor also
known as the East Coast Corridor, a new growth area earmarked for rapid industrial
development in the States of Terengganu, Pahang and Kelantan. This corridor also
forms part of the East Asian Growth Corridor (EAGC) which includes Sabah,
Sarawak, Brunei, the Philippines and Indonesia (Borneo). The EAGC was set up to
support bi-lateral economic relationships between Malaysia, Indonesia and
Philippines.

Based on its close proximity to Kuantan which is the centre for the ECID, Gebeng has
been designated as one of the key growth centres within the ECID.

The State Governments of Terengganu and Pahang envisage that the industrial areas
at Kerteh, Chukai-Kemaman and Gebeng will eventually become Malaysias leading
industrial hub, feeding the increasing demand to domestic industries and also taking
advantage of the Port of Kuatan and Port of Kemaman as a gateway to lucrative
regional and international exports.

Hence, the setting up of the Advanced Materials Plant 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 (as discussed below).

1.8.3 Positive Socio-Economic Impacts to Malaysia

Lynas proposal to set up the plant within the GIE is in line with the Pahang State
Governments development strategy to encourage and increase the establishment of
industrial operations by foreign investors. The State has created a suitable
environment for potential multinational investors in all aspects of investment, i.e. the
development of dedicated industrial estates, utilities, amenities, infrastructure and
other monetary and non-monetary incentives.

The benefits accrued by the GIE, Kuantan and the State of Pahang, as well as the
nation resulting from the setting-up of the plant in Malaysia are elaborated below.

a. Inflow of Foreign Direct Investment

The estimated total capital investment for the Advanced Materials Plant in Malaysia is
approximately RM 550 million. The operating expenditure in Malaysia for first 15
years is estimated to be RM 2.8 billion, excluding costs of the lanthanide raw
material. The proposed investment is wholly in line with the Malaysian Governments
efforts to encourage foreign direct investments into the Eastern Corridor of Malaysia.
With such a substantial investment budget, Lynas being the pioneer company
manufacturing lanthanide products, this project is expected to have a significant
positive impact on the Malaysian economy.

1-14

The lanthanides industry is inherently capital intensive and technologically advanced.
This heavy capital investment into the Eastern Corridor of Malaysia will benefit
Malaysia greatly in terms of infrastructure development, creation of business
opportunities and jobs for local Malaysian and positive spin-off effects or cluster
development of relevant supporting industries in Malaysia.

b. Export Revenue Foreign Exchange Earnings

The export revenue from the high purity lanthanide products from the Advanced
Materials Plant is projected to be RM 9.5 billion over the first 15 years. This
constitutes a major contribution to the Malaysian economy and translates into
significant cash inflow into the Malaysian economy that will spur the growth of not
only the Eastern Corridor but the country as a whole.

c. Transfer of Technology

Processing of lanthanides is a pioneer activity in Malaysia. This significant
investment into Malaysia will introduce new manufacturing processes and hence,
expose Malaysia to new technologies and expertise, particularly since the technology
in this industry is presently predominantly concentrated in China.

Lynas owns propriety technology for the recovery of lanthanide minerals from ores
and this will be employed in the proposed plant.

Lynas will also employ state of the art solvent extraction equipment and process
technologies for the purification and separation of the lanthanide elements. These
technologies enable the production of high purity lanthanide oxides that are the raw

materials for the manufacture of lanthanide metal for magnets and batteries, polishing
powders, catalysts, and glass, etc.

This degree of processing proposed by Lynas does not exist in any location outside of
China. With the application of modern technology and operation according to high
environmental standards, the operation in Malaysia will be a benchmark within the
industry in terms of scale of production, product quality, and environmental
performance.

From this pioneer investment, the transfer of technology will take place at the point
when employees are sent for training in Australia or overseas and also, by way of
regular visits by foreign technical specialists who will be sent to Malaysia to provide
onsite job training to the local staff based at the plant.

1-15

Furthermore, Lynas is currently in talks with the State Government of Pahang to
collaborate with the Universiti Malaysia Pahang (UMP) and conduct pioneer research
and development activities in Malaysia using both foreign n and local expertise. This
will greatly benefit Malaysia as it will help to improve the knowledge and skills of the
local workforce thereby creating a new area of skills specialisation which could be
applicable for the same or similar/related industries in the near future.

d. The Growth of Supporting Industries and Surrounding Areas

The proposed plant is also expected to contribute to the strengthening of industrial
linkages and enhancement of productivity through a full integration of activities
aimed at transforming the manufacturing sector in the Eastern Corridor into a
resilient, broad based and internationally competitive sector. Notably, competitiveness
of the manufacturing industry is generally enhanced by focusing on cluster
development through the deepening and broadening of inter-linked and related
activities.

Examples of inter-linked and related activities that are expected to develop in the East
Coast Corridor through the operation of Lynas plant in Gebeng are as follows:-

Chemicals;
Gas and petroleum;
Chemical reagents;
Water;
Transport/logistics;
Insurance; and
Banking.

The proposed project in Malaysia is also expected to contribute towards the
Governments efforts in driving the nation to achieve the status of a fully developed
nation by the year 2020 (i.e. the nations Vision 2020) and ensuring a strategic shift
towards knowledge-intensive, capital-intensive and high-technology based industries
linked by innovative research and development and also, cluster development of
supporting industries.

Additionally, the lanthanides plant is expected to complement the Governments
efforts in attracting the establishment and relocation of the following industries in
Malaysia with the availability of lanthanide products within Malaysia, i.e. through
import substitutions:

1-16

Hybrid vehicles
Lanthanide magnets
Flat panel displays
Ceramic capacitors
NiMH batteries
Fuel cells
Phosphors
Polishing powders

Specifically, the different applications where lanthanides play a vital role include:

Hybrid vehicles
Lanthanide magnets
Flat panel displays
Ceramic capacitors
NiMH batteries
Fuel cells
Phosphors
Polishing powders

With the establishment of the plant, it is also expected that development of new,
technologically advanced industries including small and medium size industries
(SMIs) that use lanthanide products as raw materials/components will be promoted.

e. Employment Opportunities

The proposed plant is expected to employ 398 local Malaysian and 20 expatriate
employees in the 1
st
year of operations.

The role of the expatriate employees will be to train and guide the Malaysian
employees, with the objective of further enhancing the Malaysian employees skills
and industry knowledge on lanthanide processing. It is envisioned that the local
employees will attain sufficient skills and technical knowledge to subsequently take
over the responsibilities from the expatriates.

Consequently, this will lead to further job opportunities for Malaysians not only in the
lanthanides industry but also, job opportunities for the manufacturing sector in the
Eastern Corridor on the whole as a result of the spin-off effects to related supporting
industries and sectors such as chemical, gas and petroleum, chemical reagents, water,
transport/logistics, insurance and banking sectors, etc.

1-17

f. Economic Benefits

The proposed plant in Malaysia is expected to bring about positive multiplier effects
to the Malaysian economy. Positive multiplier effects, resulting from the employment
of local and foreign personnel and expenditure by both the company and its
employees (both local and foreign) on daily necessities, telephone and utilities,
support services such as transport and logistics, banking, insurance etc. and also, tax
revenues to the Government is expected.

Based on a multiplier effect factor of 2 (i.e. 2 x multiplier effect of business expenditure
and project operating costs), the total direct and indirect contributions to the Malaysian
economy over the first 15 years of operations (year 2008 2022) by the proposed plant is
estimated to be RM6.04 billion. In addition, Lynas proposed operations in Malaysia are
projected to generate approximately RM42 million in tax revenue for the Malaysian
Government over its first 15 years of operations (year 2008 2022).

The setting up of the plant will also ensure the following:

Counter-flow of foreign currency by reducing Malaysian imports of
lanthanide products, hence, benefiting Malaysia in terms of its balance of
payments position;

Increased export revenue that results in a favourable position in the
countrys balance of payment position; and

Creation of demand for local supplies of relevant raw materials and
components such as chemical reagents (hydrochloric acid, sulphuric acid,
magnesium oxide,
lime, etc.), gas, etc. which is expected to encourage the shift towards the use of
local contents by other relevant industries.

1.9 OBJECTIVES OF THE STUDY

The objectives of this EIA study are as follows:

To select project options which are environmentally sustainable in relation to
plant siting, landuse compatibility and plant operations;

To identify the potential sources of environmental pollution arising from the
construction and operation of the proposed plant within the GIE and to assess the

Direct and indirect significant impacts on the natural, social and economic
environments.

1-18

To recommend suitable mitigation measures that can be incorporated into the
design and operation of the plant thereby reducing the predicated impacts to
sustainable levels which meet the prevailing regulatory requirements.

To identify residual impacts that may potentially exist even after implementation
of mitigation measures, and to outline the requirement for an Environmental
Management Plan which includes environmental audits and monitoring programs
for the construction and operation phases of the project.

To provide an outline for an Emergency Response Plan to be developed prior to
the commencement of the plant operations.

1.10 STRUCTURE OF THE REPORT

The remaining of this EIA report is structured as follows:

Chapter Two: Project Description provides a detailed description of the activities
carried out during the construction and operational phases of the project.

Chapter Three: Project Options addresses the various options considered in selecting
the site and the proposed plant operations and evaluates the project options by
weighing the benefits of the Build-Out Option and No-Build Option.

Chapter Four: Existing Environment describes the environmental conditions within
a 3-5 km radius of the Project site prior to the implementation of the project. The
environmental quality data presented here represents the baseline data for the site.

Chapter Five: Potential Significant Impacts and Recommended Mitigation
Measures assesses the potential environmental impacts arising from the
implementation of the project during both the construction and operational phases and
recommends mitigation measures.

Chapter Six: Environmental Management Plan (EMP) identifies the residual
impacts and outlines a suitable Environmental Monitoring and Audit Programme.

Chapter Seven: Emergency Response Plan (ERP) describes the requirements for the
preparation of an ERP for the operational phase of the plant.

Chapter Eight: Summary and Conclusions which summarises the findings and
conclusions of the study.

1-19

1.11 LIMITATIONS OF THE REPORT

The conclusions presented in this report represent ENVIRONs professional judgment
based on information made available during the course of this assignment and is true
and correct to the best of ENVIRONs knowledge as of the date of the assessment.
ENVIRON made reasonable efforts to verify the written and oral information
provided in this assessment. The findings, opinion and conclusions presented in this
report represent ENVIRONs best professional judgment based upon the information
available and conditions existing as of the date of the report preparation. In
performing its assignment, ENVIRON must rely upon information obtained from
Lynas, publicly available information, government agencies and information provided
by third parties. Accordingly, the conclusions in this report are valid only to the extent
that the information provided to ENVIRON was accurate and complete. ENVIRON
found no reason to question the validity of information received unless explicitly
noted elsewhere in this report.

Gebeng Industrial Estate, Kuantan,Pahang, Malaysia

2-1

CHAPTER TWO
2.0 PROJECT DESCRIPTION

2.1 PROJECT LOCATION

The proposed rare earths processing plant will be located on 100 ha of industrial land
within the Gebeng Industrial Estate (GIE) in Kuantan, Pahang.

This chapter describes the various activities envisaged during the pre-construction,
construction and operational phase of the project.

2.2 PRE-CONSTRUCTION PHASE

Activities undertaken during this phase are focused primarily on obtaining physical data
on the existing conditions at the project area. Key activities include:

Geotechnical investigation;
Land topography survey;
Identification of ecological (terrestrial flora and fauna) resources;
Environmental baseline monitoring for ambient air quality, river water quality, and
boundary noise levels; and
Soil and groundwater investigation.

During this phase, the conceptual design of the proposed plant and its associated
facilities will evolve according to information and analyses obtained on the existing
physical conditions and baseline environment at the site.

The geotechnical investigation and topographical survey of the site has been carried out in
October/November 2007. The data obtained was used to determine the ground elevation
and physical features of the project site for use in earthworks preparation, infrastructure
planning, plant design platform level and residue storage facilities planned within the site.

For the activities listed above, some removal of the undergrowth and shrubbery was
necessary. Equipment used were specialised drilling rigs as well as hand-augers and
mobilisation of equipment and personnel were by small lorries. However, these activities
were completed within a short duration with only minimal and temporal disruption to the
environment.

2-2

A site reconnaissance and an environmental baseline survey were carried out from the in
October 2007 by ENVIRON. During this baseline survey of the site, the existing terrestrial
ecology at the site was also evaluated. The baseline survey comprised the following:

Monitoring of ambient air quality and boundary noise levels at the site;
Monitoring of ambient air quality and boundary noise levels at four locations within
the site;
Establishment of 7 borewells within the site and collection of soil and groundwater
samples; and
Collection of river samples during both the high and low tides from Sungai Balok.

The environmental impacts arising from these activities were minimal.

Overall, the activities carried out during the pre-construction phase are not significant.

2.3 CONSTRUCTION PHASE

The principal activities envisaged during the construction phase are as follows:

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.

2.3.1 Temporary Facilities
Upon commencement of the construction phase, the typical structures that will be erected
at the project site include a site office, temporary warehouse cum fabrication yard,
construction workers camp and sanitary facilities. In most instances, the site office will
be in the form of transportable cabins and the warehouse typically constructed as an
enclosed wooden structure or shed. The warehouse will be used for the storage of
equipment and material and; also function as a fabrication yard.

Workers employed by Lynas for construction activities will either be housed within the
site or housing facilities will be provided at the nearby residential areas. In the event the
workers are housed within the site, a transit construction workers camp will be set up
on-site to house the workers. The workers camp will generally comprise wooden
structures provided with the necessary facilities. Some site clearing and earthworks
together with temporary utility provisions will be carried out onsite for this purpose.
Basic amenities, i.e. water supply, electricity and sanitation facilities will be provided.
Sanitation facilities will be in the form of portable toilets with designs approved by the
Department of Sewerage Services, Ministry of Housing and Local Government.

2-3
In hiring the construction workforce, priority will be given to Malaysians. However, if
foreign labour is required to supplement the local workforce, an official hire process will
be adhered to prevent the engagement of illegal foreign nationals at the site.

2.3.2 Land Clearing

As the proposed plant site has been largely cleared, only the existing remnant peat
swamp vegetation and other secondary invasive species will need to be cleared.

Information on the cut and fill areas, excavated volume for disposal and quantity (and
source) of backfill required were not available at the time of reporting. All excavated
material will be reused within the site. There will be no removal of excavated material
from the site.

The burning of vegetative biomass is strictly prohibited under the Environmental Quality
(Clean Air) Regulations 1978.

2.3.3 Transportation of Building Materials and Machinery

Major plant and equipment for the construction activities are likely to include:

Piling rigs
Bulldozers
Excavators
Cranes
Lorries/transport trucks

Construction machinery and materials will be transported to the site in low loaders and
heavy load bearing transport vehicles via the main Gebeng By-pass Road and the main
entrance into the GIE. The movement of these vehicles may cause traffic congestion
during peak hours. Impedance to the normal traffic flow can be minimised by avoiding
the peak traffic hours (i.e. 7.00 am 9.00 am and 4.00 pm 7.00 pm).

2.3.4 Infrastructure and Utility Development

Drainage

The drainage network within the site will be designed to convey the increased surface
runoff from the site. Although, the drainage system is normally designed to follow its
natural course, there will be with some degree of realignment. Drains will be designed as
unlined channels. The site drainage will be designed to lead into a stormwater detention
pond located close to the southern boundary of the site. The detention pond will provide
flood attenuation during peak rainfall incidences. The overflow from this detention pond
will find its way into the existing external earth drain which runs along the southern

2-4
boundary of the site. The drain flows in a westerly direction to discharge into Sungai
Balok.

The construction of drains within the site would involve excavation of trenches, laying of
the bedding (normally crusher run or sand), followed by the laying and jointing of the
pre-cast sections. Options for drains may include closed conduit systems or covered
rectangular channels discharging into open main/monsoon drains.

During the construction phase, an adequately designed silt trap will be constructed at the
southwestern corner of the site. This area is similar to the area allocated for the
stormwater detention pond during the operational phase.

Temporary roads will be constructed for the entry/exit to the site and for the movement
of construction machinery and vehicles within the site during the construction phase. The
roads will generally be laid with crusher-run. Some of these roads may be converted to
permanent roads for the operational phase of the project. All road exits which lead out of
the site will be provided with a wheel washing trough to prevent the carry over of mud
and sediments onto public roads.

Utility works will involve trenching to lay the respective conduits for potable water
supply, sewage, natural gas, telecommunication cables, electricity cables; and
construction of utility structures such as water storage tanks, pump houses, sewage
treatment plants (STPs) and electrical sub-station. These structures should be suitably
located to minimise interruption to traffic flow during the operational phase and adverse
visual impacts during maintenance activities. As far as possible, trenching works should
be coordinated with road and drainage works.

2.3.5 Construction Activities

Building construction will proceed upon completion of earthworks and will involve the
construction of sub-surface and foundation platforms, erection of reinforced concrete
frames and construction of buildings/structures.

Specialised rigs, piles (either steel or more commonly, pre-cast concrete) will be
mobilised followed by the pile driving process. There are various forms of pile-driving
techniques involving hydraulic injection, boring and the conventional drop hammer. The
drop hammers are noisier comparatively and due consideration will be given in selecting
a more quieter piling method.

Other construction activities will involve the transport of construction materials such as
cement, sand, aggregate, formwork and steel reinforcement bars to the site. Ready-mixed
concrete will also be imported to the site unless a cement batching plant is set up within
the site.

2-5

2.3.6 Landscape and Revegetation

Once the building activities are completed, the site will be landscaped and revegetated.
Vegetation will be planted along the plant boundary for noise attenuation and filtering of
air pollutants.

All denuded areas will be revegetated or paved as soon as possible to minimise erosion
risks especially during the monsoon season.

2.4 OPERATIONAL PHASE

2.4.1 Concentration Plant (Mt Weld, Western Australia)
The concentration process will be undertaken at the Concentration Plant located within
the mine site at Mt. Weld in Western Australia. The main processes include:

Crushing
Milling
Rougher flotation and three stages of scavenger flotation
Five stages of cleaner flotation
Concentrate thickening and filtration
Tailings, concentrate storage and packaging, and discharge to storage facility

The flotation circuit will consist of one stage of rougher flotation and three stages of
scavenger flotation, with the combined rougher-scavenger concentrate fed to a cleaning
circuit consisting of five stages of cleaner flotation. The final product will be a
concentrate assaying approximately 40% lanthanide oxide basis (LnO), at a design
recovery of 63%. Each flotation stage will include conditioning tanks as required for
addition of the following:

Steam for heating.
Sodium hydroxide solution for pH modification.
Sodium silicate solution for dispersion.
Sodium fluorosilicate and sodium sulphide solutions for gangue depression.
Fatty acid collector, DQ.

The final lanthanide concentrate will be de-aerated and mixed with flocculant and lime
before being fed to the concentrate thickener. Thickened concentrate will be pumped to a
plate and frame filter for dewatering. The filter will produce a filter cake with <20%
moisture, and a filtrate solution, which will be returned to the concentrate thickener for
recovery of ultra-fine solids.

It is envisaged that the lanthanide concentrate filter cake will be directly bagged (2.2
tonne bags or 1 x 20 tonne bag) and placed into sea containers on weigh cells to hold
exactly 20 tonnes of material. The sea containers will then be loaded onto road trains for

2-6
haulage to Leanora where they will be placed on to the rail for haulage down to
Fremantle for shipment to the Advanced Materials Plant in Malaysia.

Approximately 66,000 tonnes of lanthanide concentrate at < 20% moisture content will
be shipped annually from the Port of Fremantle in Western Australia to the Eastern
Wharf of the Port of Kuantan in Pahang. This quantity will be shipped weekly via 60 to
80 sea containers movements per week. The sea containers will then be unloaded at the
port after the standard port and customs clearance procedures.

The sea containers will be loaded onto trucks and delivered to the advanced plant site
within the Gebeng Industrial Estate which is located about 3 km west of the port. On an
average, the transportation frequency is expected to be 6 days per week 13 deliveries per
day.

The specific radiation activity (total activity) of the ore is 61.0 Bq/g. The thorium and
uranium content of the ore are 1600 ppm (as ThO
2
) and 29 ppm (as U
3
O
8
) by weight
respectively. The Malaysian Nuclear Agency, the radiological consultants appointed by
Lynas are presently in the midst of determining radiation safety issues pertaining to
lanthanide concentrate storage, handling and transport.

2.4.2 Cracking and Separation Plant
The main processes involved in the Cracking & Separation Plant include:

Lanthanide Concentrate Handling
Lanthanide Concentrate Cracking
Leaching
Upstream Extraction
Downstream Extraction
Product Finishing

A block flow diagram representing the processes within the Cracking and Separation
Plants is presented in Exhibit 2.2.

2.4.2.1 Lanthanide Concentrate Cracking
A diesel powered loader will be used to transfer the lanthanide concentrate from the site
stockpile into the concentrate feed hopper (capacity of 10m
3
).

From the hopper, the concentrate will be fed onto a belt conveyor and transported to the
cracking plant which will consist of two parallel processing trains. The lanthanide
concentrate will be fed via two belt weighfeeders into the concentrate-acid mixers, where
sulphuric acid (98%) will be added. The mixed slurry will be pumped into the rotary
kilns where it will be heated to approximately 650C over a period of 2.5 hours. The
products from the kilns will comprise cracked concentrate and tail gas.

2-7

The kilns are fuelled by hot gas generated by the combustion of Liquified Petroleum Gas
(LPG); gas flow will be automatically controlled by the temperature at the hot end of the
kiln. To allow for future expansion of the plants processing capacity, an area has been
provided in the layout for two (2) additional rotary kilns. These new kilns will be located
in parallel to the original two (2) kilns.
Cracked concentrate discharges from the kiln into the leach tanks. Oversize from the kiln
discharge will be collected in a skip, and will be crushed prior to feeding into the water
leach circuit.

2.4.2.2 Leaching and Neutralisation
The soluble rare earth sulphates will be recovered from the cracked concentrate in a three
stage leaching process. After the primary leach, the slurry will be filtered in two (2) filter
presses to enable solid-liquid separation. The primary filter cake will be subjected to a
second stage of leaching and filtration. Filtrate from this stage will be recycled to the
primary leach circuit and the filter cake will be mixed with water for the third stage of
leaching. After filtration, the final solids residue, which is referred to as the Water
Leached Purification (WLP) solids, will be stored onsite in the secure WLP storage cell.
Filtrate from the tertiary leach is recycled to primary and secondary leaching.

To remove some of the soluble impurities, the primary leach filtrate will be neutralized
with magnesium oxide powder to achieve a pH of 3.5-4.0. The neutralized slurry will be
filtered in two (2) filter presses. The filtrate from this operation will be filtered through a
polishing filter press before being transferred to the first solvent extraction plant.

The filter cake from the neutralization process will be leached with weak sulphuric acid
to recover precipitated rare earth oxide. The residue from this process will be filtered
through a filter press and the filtrate will be recycled to the primary leach. The filter
cake will be water washed and filtered with the tertiary leach product to become part of
the WLP solids.

2.4.2.3 Extraction
Solvent extraction will be used to purify, separate and concentrate the lanthanides before
their precipitation into products.

In solvent extraction, the lanthanide elements will be selectively extracted from the
aqueous phase into an organic phase using a battery of mixer-settlers. A mixer settler
refers to a combination of an agitated tank, where the aqueous and organic phases are
mixed and the metal extraction occurs, and a rectangular settling vessel where the phases
separate into two distinct layers. The organic and aqueous phases will flow through the
battery of mixer-settlers counter-current to one another to achieve the optimum levels of
organic loading, separation and recovery. As the aim of each stage of extraction is
different, the conditions within the mixer-settlers will be controlled to remove part of, or
all lanthanide elements to the organic phase from aqueous phase.

2-8

To further improve separation efficiencies, the loaded organic phase will in scrubbed
with either dilute sulphuric or dilute hydrochloric acid. Scrubbing equipment will be
similar to the extraction equipment, involving a group of mixers and settlers.

The scrubbed organic phase, which is loaded with lanthanides, will then be stripped by
contact with either 4.5M or 6M hydrochloric acid. Stripping is the transfer of lanthanides
from the organic back into the aqueous phase. The lanthanides in the aqueous strip
solutions will either be transferred to the next extraction system for separation into
individual lanthanide elements or used to produce a mixed lanthanide product directly.

After stripping, the organic phase will be washed with water in additional mixer-settlers.
The wash solutions will contain hydrochloric acid, and will be routed to the hydrochloric
acid preparation circuit for re-use. The washed organic will be stored in a tank, from
where it will be continually recycled to extraction.

A total of five (5) organic liquids will be used for extraction in the cracking and
separation plant. These are:

Extractant: P204, Di(2-ethylhexyl) phosphoric acid (C
16
H
35
O
4
P)
Extractant: P507, 2-ethylhexyl phosphonic acid mono-2- ethylhexyl ester (C
16
H
35
O
3
P)
Extractant: N235, Iso Octylamine
Modifier: Isooctyl alcohol, C
3
(C
2
H
5
)C
5
H
10
OH
Diluent: Kerosene

Hydrochloric acid (0.5M, 4.5 and 6M) will be used in solvent extraction. Concentrated
hydrochloric acid (> 30%) will be transported by trucks to the Cracking and Separation
Plant area and stored in 3 storage tanks. The acid will be pumped into agitated dilution
tanks located within the extraction plant by two concentrated acid feeding pumps.
Diluted hydrochloric acid will be fed to the extraction plant from these tanks.

Sodium hydroxide (6M) will also be used in the solvent extraction plant. The sodium
hydroxide solution (30wt %) will be transported by trucks and stored in a storage tank.
The solution will be pumped via two pumps to the agitated dilution tanks located within
extraction plant. Diluted sodium hydroxide will be fed to the extraction plant directly
from these tanks.

The extraction process is divided into two systems:
Upsteam Extraction; which has a sulphate based aqueous phase and uses P204
solvent for extraction, and
Downstream Extraction; which has a chloride based aqueous phase and uses
P507 solvent for extraction.

2-9

Upstream extraction consists of three (3) extraction circuits for the purification of the
lanthanides as a group:

SX1 SEG elements extracted from the LCPN elements
SX2 bulk extraction of the LCPN and the remaining SEG elements from SX1
raffinate.
SX3 In this battery, N235 is used to remove iron from SX1 and SX2 strip
solutions.

Downstream Extraction employs three (3) extraction circuits for the separation of the
lanthanides.

SX5 LC-PN separation, where PN are extracted away from the LC elements.
SX6 L-C separation, where C is extracted from the SX5 raffinate
SX6 this battery also includes a N235 extraction to remove Fe from the C strip
solution
SX7 Didymium Purification, where the SEG elements are extracted from the
SX5 strip solution which contains the PN elements.

Area for expansion of the extraction process has been provided for.

2.4.2.4 Product Finishing
In the post-treatment stage, the lanthanide chloride strip solutions will be purified, to
remove impurities, and precipitated into carbonate or oxalate forms.

The following lanthanide products will be produced;

a) LCPN Carbonate
LCPN chloride solution from SX2 will be purified by the addition of sodium carbonate
solution to achieve pH 4. The neutralized slurry will be filtered in a filter press to remove
the solid impurities which will be recycled to the leach circuit. The filtrate will be routed
to SX5 or to the LCPN precipitation circuit, for precipitation with sodium carbonate
solution. The LCPN carbonate product will be transferred to a centrifuge for solid liquid
separation and washing. The wastewater generated from the washing process will be
transferred to the High Density Sludge (HDS) plant for treatment.

b) SEG-HRE Carbonate
SEG and HRE chloride solution from the SX1/SX3 extraction lines will be neutralised
with magnesia to a pH of 2.5. The neutralised solutions will be filtered in a filter press to
remove any precipitated solids which will be releached with acid to recover co-
precipitated REO. The final residue from the re-leach will be discharged and the filtrate
will be recycled within the SEG/HRE area.

2-10

Carbonate salts will be precipitated from the purified SEG/HRE solutions using sodium
carbonate. The carbonate products will be transferred to a centrifuge for solid liquid
separation and washing. The wastewater generated from the process will be a sodium
chloride solution and will be transferred to the HDS system for treatment.

c) LaCe Carbonate
LC chloride solution (raffinate from SX5) will be purified by the addition of sodium
sulphide, barium chloride and sodium sulphate solutions. The neutralized slurry will be
filtered in a filter press to remove the solid impurities which will be discharged from the
circuit. The filtrate will be routed to the precipitation circuit, for precipitation with
sodium carbonate solution. The LC carbonate product will be transferred to a centrifuge
for solid liquid separation and washing. The wastewater generated from the washing
process will be transferred to the High Density Sludge (HDS) plant for treatment.

d) Cerium Carbonate
C chloride solution from SX6 will be purified by the addition of sodium carbonate
solution to achieve pH 4. The neutralized slurry will be filtered in a filter press to remove
the solid impurities which will be recycled to the leach circuit. The filtrate will be routed
to the C precipitation circuit, for precipitation with sodium carbonate solution. The C
carbonate product will be transferred to a centrifuge for solid liquid separation and
washing . The wastewater generated from the washing process will be transferred to the
High Density Sludge (HDS) plant for treatment.

e) Lanthanum Carbonate,
L chloride solution (raffinate from SX6) will be purified by the addition of sodium
sulphide, barium chloride and sodium sulphate solutions. The neutralized slurry will be
filtered in a filter press to remove the solid impurities which will be discharged from the
circuit. The filtrate will be routed to the precipitation circuit, for precipitation with
sodium carbonate solution. The L carbonate product will be transferred to a centrifuge
for solid liquid separation and washing . The wastewater generated from the washing
process will be transferred to the High Density Sludge (HDS) plant for treatment.

f) Lanthanum Oxide
Lanthanum oxide will be produced by calcining Lanthanum carbonate at a temperature
of 900
C in the LPG-fired tunnel furnace. The tail gas discharge from lanthanum
calcinations process will contain CO
2
and H
2
O, and no hazardous elements, and will be
emitted to the atmosphere.

2-11

g) Dydimium (Dd) Oxide
Dydimium (Dd) is a mixture of Pr and Nd. The chloride solution containing Dd is the
SX7 raffinate and will be precipitated with oxalic acid, washed and centrifuged to
produce Dd oxalate. The wastewater generated from the Didymium precipitation process
is a dilute hydrochloric acid solution, and will be transferred to HDS for neutralisation.

Didymium oxide will be produced from the calcination of didymium oxalate at a
temperature of 900
C in the LPG fired tunnel furnace. Tail gas discharge from

Didymium calcinations process will contain CO
2
and H
2
O with no hazard elements, and
will be emitted to the atmosphere.

2.4.3 List of Equipment
The list of main equipment to be installed at the plant is presented in Table 2.1 below.

Table 2.1: List of Major Equipment within the Advanced Materials Plant

Description No of Units
Pressure Filters 20
Rotary Kilns 2
Waste Gas Treatment Unit 1
Solvent extraction cells 200
Centrifuges 27
Tunnel furnaces 2
Boilers 2
Water treatment Bio-reactors 3


2-12

2.4.4 List of Reagent and Annual Consumption
Reagents consumed at the plant and their anticipated annual usage quantities are
presented in Tables 2.2.

Table 2.2: Annual Reagent Consumption for the Cracking & Separation Plant

Reagent Annual Consumption at Start-up (tonnes)
H
2
SO
4
(98%) 110,238
HCl (31%) 146,774
MgO 23,348
BaCl
2
.2H
2
O 602
Na
2
CO
3
19,632
P204

496
P507 184
NaOH (30%) 81,120
Na
2
SO
4
93
Na
2
S 164
H
2
C
2
O
4
8,924
Kerosene 1,720
N235 Mixed 24
Hydrated Lime 111,386
Iso-octyl alcohol 24

Separation of the incompatible reagents, sodium fluosilicate and the alkalis has been
considered when developing layouts. The dry reagents are separated in the storage shed
by a barrier, while the wet chemicals are separately bunded with dedicated sump pumps.

2.4.4.1 Reagent Storage & Handling
a. Caustic Soda
Caustic soda or sodium hydroxide will be supplied to the plant in 24 tonne bulk tankers
as a 30% solution w/w. The tanker will discharge into a 330 m
3
storage tank located
within the tank farm proposed to the northwest of the plant. The solution will be pumped
at full strength via individual pumps to the plant dose points.
b. Sodium Sulphide
Sodium sulphide will be supplied in 1 tonne bulk bags. The main plant storage will
therefore be held as dry powder. The powder will be mixed to a 10% solution in a single-
stage agitated tank.

2-13

A hoist will raise the bags to a bag breaker located above an agitated tank. During
reagent mixing, the mix tank will be isolated and the dosing pumps will draw from a
small buffer tank. The mixing / storage tank will be filled with water (10 m
3
) to allow the
target concentration to be met by the addition of 1 tonne of powder. A fume extraction
fan will be provided to remove any harmful gaseous by-product. This tank volume is
adequate for 50 hours operation. Distribution to the plant will be by a diaphragm dosing
pump.
c. Flocculant
The flocculant mixing system will be located separately in the HDS thickener area. A
reagent shed for storage of dry chemicals and reagent drums will be located adjacent to
the Product Finishing Area.

Flocculant will be supplied in 25 kg bags on 900 kg pallets. The bags will be loaded by
hand into a dry powder hopper. The dry powder will be metered into a dry transfer
system and will be pneumatically transported to a wetting head. In the wetting head, the
powder will be contacted with raw water from a number of spray heads. This concentrate
solution will discharge into an agitated tank where water will be added to achieve a
0.25% solution.

This solution will be transferred into a storage tank for distribution to the plant. The
facility will be a stand-alone package that will be controlled by a vendor-supplied PLC.
d. Hydrated Lime
Hydrated lime will be used scrubbing of kiln off-gas and for the neutralisation of waste
waster. Lime will be supplied in bulk and transferred into a silo before mixing to a 20%-
slurry. The milk of lime slurry will be pumped to user locations in waste gas treatment
and HDS neutralisation areas.

The mixing-storage tank will consist of two tanks (30 m
3
each) that will be large enough
to allow incremental addition of water and lime powder. When the tank levels have
declined the tank will be topped up with raw water to a predetermined level and the dry
lime powder added. This tank volume is adequate for 4 hours operation so addition of
lime with be on an as-required basis.

The reagent mixing area will be bunded separately and will be provided with two sump
pumps for clean up.
e. Sulphuric Acid
Sulphuric acid (98% concentration) will be trucked into the site and stored in three (3)
storage tanks (250 m
3
) within the bunded tank farm. The acid will be pumped into
elevated tanks from where the acid will be meter-fed into the concentrate-acid mixers.

Sulphuric acid will be diluted and used to scrub lanthanide impurities from the organic
phase in the Extraction Units. The diluted acid will be stored in two (2) tanks within the
tank farm area.

2-14

f. Hydrochloric Acid
Hydrochloric acid (33% concentration) will be trucked into the site and stored in three
(3) storage tanks (330m
3
each) within a bunded tank farm. The acid will be pumped for
dilution in the extraction sections where it is prepared to several concentrations for use in
the solvent extraction processes.
g. Magnesium Oxide (MgO)
Magnesium Oxide or magnesia will be imported in 1t bags and transported to site in
open truck or sea container. This material is a free flowing white powder that easily
absorbs carbon dioxide and moisture. The bags will be unloaded and stored in the
purification section of the water leaching building - close to the point of use. The bags
are hoisted above and emptied into hopers with screw feeders that deliver the material to
the process.
h. Sodium Carbonate (Na
2
CO
3
)
Sodium Carbonate or soda ash will be imported in 1t bags or bulk and transported to site
in sea container or pneumatic road tanker. This material is a free flowing white powder
that easily absorbs moisture. The bags will be unloaded and stored in the post treatment
building - close to the point of use. The bags are hoisted above and emptied into hopers
with screw feeders that deliver the material to the process.
i. Oxalic Acid (H
2
C
2
O
4
)
Oxalic acid will be imported in 1t or 50kg bags and transported to site in open truck or
sea container. This material is a free flowing white powder that easily absorbs moisture.
The bags will be unloaded and stored in the post treatment building - close to the point of
use. The bags are hoisted above and emptied into an agitated tank.

The magnesia, soda ash and the hydrated lime will be stored separately within the plant
due to the volumes consumed, and to ensure these materials are stored separate from
acidic chemicals.
j. Industrial Kerosene
A low volatility and high flash point kerosene (65
0
C) will be used as the base solvent for
the extraction liquid. The kerosene will be received in truck tanker or in 200 litre drums,
and unloaded into two storage tanks from where the solvent will be pumped to blending
tanks for mixing with other organic solvents.
k. D2EHPA (P204)
An acidic phophorus extraction reagent known as D2EHPA or P204 will be used as the
extraction agent. The flash point of this material is 206
0
C. This reagent will be received
in 200 litre drums which are emptied by pumping directly into the extraction circuits.

2-15

l. P507
An acidic phophorus extraction reagent known as P507 or PC-88A or Ionquest 801 will
be used as the extraction agent. This reagent will be received in 200 litre drums which
will be emptied by pumping directly into the extraction circuits.
m. N235
A tertiary amine N235 will be used as an extraction agent for the removal of impurities
(metals) in the extraction process. This reagent will be received in 200 litre drums which
will be emptied by pumping directly into the extraction circuits.
n. Iso-Octyl Alcohol
Iso-Octyly alcohol will be used for dilution of naphthenic acid and N235. This reagent is
received in 200 litre drums and emptied by pumping directly into the extraction circuits.

Iso-octyl alcohol, P204
,
P507 and naphthenic acid will be transported in 200 litre HDPE
drums and stored within the chemical store until required in the process. The drums will
be transported to the extraction buildings by forklift and mixing of these chemicals will
be carried out at the point of use within the plant.
o. Other Chemicals
Other chemicals received in solid powder form include BaCl
2
.2H
2
O, Na
2
SO
4
, and Na
2
S
which will be transported to the site in 1t bulker bags or 50kg bags and stored within the
chemical store or dedicated storage areas close to the point of use.

Barium chloride is a white solid that absorbs moisture. The 1t bags used to stored the
compound will be hoisted above and emptied into a mixing tank to prepare the barium
chloride solution. This solution will be added to lanthanide chloride solution to remove
sulphates.

Sodium sulphate is a white solid that absorbs moisture, and will be imported in 50kg
bags. These bags will be emptied into a mixing tank and then added to the lanthanides
chloride solution to remove radium.

2.4.5 Utilities

Process Water Requirement

The process water requirement for the Advanced Materials Plant is expected to range
between 330 m
3
/hr and 550 m
3
/hr under steady state demand. The plant will source the
water from the Pahang Water Supply Department.

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. The
final treated effluent will be discharged from the plant at a rate of between 330 m
3
/hr and
500 m
3
/hr.

2-16

Process Air Requirement

Two electric driven compressors will be supplied on a duty / standby arrangement. The
two compressors will be connected via a common manifold to supply normal plant and
instrumentation air requirements. An air dryer will be fitted to produce air of a quality
suitable for instruments. The compressors will be controlled by vendor-supplied PLCs.

A single low-pressure air blower will be provided to supply the air required for the
flotation circuit. The blower will be fully manual in operation and will supply low-
pressure air to the whole flotation plant via a series of header pipes.

The plant and instrument air compressors have been located on the northern side of
flotation area. This location allows the compressors to be located adjacent to the highest
usage areas. The blower area is located at the western end of the flotation area, to provide
a convenient piping route.

Energy

Liquefied Petroleum Gas (LPG) will be used within the site as fuel for the two rotary
kilns, the steam boilers, and the product furnaces. The annual supply requirement is
12,820,000 Nm
3
/yr.

The LPG will be sourced form Petronas.

Steam Generation

Steam will be generated from on-site boilers for process heating and is used in the
concentration and post treatment processes. The annual steam requirement is expected to
be 80,000 tons/yr.

Electricity

Electricity will be supplied by Tenaga Nasional Berhad, the National Electricity Board.
A sub-station will be constructed onsite to house transformers required to step down the
incoming supply of 33kV.

.

3-1
CHAPTER THREE
3.0 PROJECT OPTION

3.1 INTRODUCTION

Several options were considered in the planning stages of the project. These include site
selection, technological alternatives and; the Build Out or No Build options which are
based on assessments of beneficial and adverse environmental and socio-economic
impacts brought about by the construction and operation of the Advanced Materials Plant
in Kuantan, Pahang.

3.2 SITE SELECTION

During the initial planning stage of the project, Lynas undertook a project feasibility and
site selection exercise. After a global search for potential viable sites for the
establishment of the Advanced Materials Plant, Lynas selected suitable industrial sites in
three (3) different countries, namely China, Abu Dhabi and Malaysia.

The decision to locate the plant outside Australia was solely based on economic
considerations. Despite receiving environmental approvals in Australia, the isolated
location of the mine site (in Laverton, Western Australia) resulted in significantly higher
capital costs for plant and infrastructure construction, which were deemed prohibitive.
The operational costs associated with an isolated location, such as the cost of shipping
reagents and transporting labour force (by air) was also extremely high. The coastal
regions of Western Australia also lack the required chemical industry infrastructure
required for the refining of high purity lanthanides that can be found in the three selected
suitable industrial sites outside Australia.

In deciding the final site for the plant, numerous visits were undertaken to the actual
sites in these countries, discussions held with the local regulatory and industrial
development agencies, and several critical factors influencing the economic feasibility of
the plant operations were considered. The key factors that ultimately affected the siting
location of the plant in Malaysia are briefly outlined below.

China

China was the original proposed location given the readily available expertise and
technologies in lanthanide processing. However, the decision was later reversed as a
result of the Chinese Governments decision to impose export quotas on ores that are
shipped in from outside China for processing. This decision by the government would
subject the Lynas Group to lose a significant competitive advantage (i.e. diversification
of supply source for international customers). In addition, the removal of VAT (Value
Added Tax) rebates for exports would significantly impact the economics of the
proposed plant. The inevitable increase in state control of the lanthanides processing
industry in China was thereby the main factor in reversing the decision to locate the
proposed plant in China.

3-2

Abu Dhabi

The main reason for not proceeding with the siting of the plant in Abu Dhabi was the
lack of transparency with respect to the project approval process involving the regulators.
This is disadvantageous as this factor does not allow the Lynas Group to properly
manage and develop key milestones in developing the proposed plant. With regards to
supporting infrastructure, the port facilities and associated industrial-related
infrastructure within the earmarked area were observed to be developing rapidly but less
advanced than Malaysia and, the rate of development observed would not meet the
project implementation timeframe. The environmental regulations were also observed to
be not comprehensive enough to validate the sustainability of the plant operations. As
part of the lanthanides production supply chain, Lynas will need to show its customers
that the plant operations are environmentally-friendly and sustainable.

In view of the above, Lynas finally selected Malaysia for the setting up of the plant. The
criteria that favoured the Malaysian site are summarized in the section below,

3.3 GEBENG INDUSTRIAL ESTATE, KUANTAN, PAHANG, MALAYSIA

The Gebeng Industrial Estate (GIE) is part of the growth corridor earmarked for rapid
industrial development in the States of Kelantan, Terengganu and Pahang.

The GIE was established by the Pahang State Development Corporation (PASDEC) to
actively promote the establishment of chemical and petrochemical facilities. The
industrial estate, one of the largest industrial areas in the region, covering over 9, 600 ha,
was developed as an industrial forerunner in the East Asia region for the development of
petrochemical (especially the propylene-based industries) and chemical based industries.
The industrial estate is a self-contained estate, equipped with the necessary infrastructure
facilities and utilities. Phases I, II and III of the GIE have been fully developed. The
development of the final phase, Phase IV is expected to commence in the near future.
The establishment of the proposed plant within GIE will ensure compatibility with the
surrounding facilities and thereby reducing environmental, health and safety impacts that
may arise from conflicting operations. The Phase II area is occupied by the MTBE and
Propylene plants, Eastman Chemicals, BP Chemicals, WR Grace, Kaneka and Nikko
Fine Products which encompasses some 2100 acres. Phase III of the development,
covering an area of 2500 acres accommodate three large plants, developed by BASF in
conjunction with PETRONAS as joint venture project. Another chemical plant,
Polyplastics Asia Pacific Sdn. Bhd. is also located on the Phase III area. As the GIE is
also advantageously sited close to Kertih where raw material (petroleum, its by-products
and natural gas) for these industries are readily available, the industrial area expanded
rapidly, spurred mainly by foreign investments.

3-3

3.3.1 Strategic Location in the Region

The setting-up of the proposed plant within the GIE in Pahang is deemed strategic
due to its close proximity to potential regional markets such as Australia, China,
India, Indonesia, Japan, Qatar, Saudi Arabia, South Korea and the United Arab
Emirates.

3.3.2 Accessibility to Key Infrastructure and Available Utilities

Port Facilities
The proximity of the project site to the Port of Kuantan is also one of the important
factors considered. The distance from the site to the port area is relatively short, as the
port is located approximately 4 km east of GIE. In addition to its close proximity, the
port is the major entry and exit point for sea borne cargo in the East of Peninsular
Malaysia. The port is a man-made, deep-water, all weather port handling over 4 million
tonnes of shipping annually and has been operational since 1984. The Kuantan Port was
developed as a significant part of the East Coast Industrial Development Corridor. The
port is fully equipped to handle a wide variety of cargo, and has well-equipped
conventional, multi-purpose, container and liquid bulk wharves. The port is linked
globally through a network of shipping services, including container liner shipping
services of leading lines calling at its dedicated container terminal.

The dedicated facilities for petrochemical vessels and cargo handling include two
specialised liquid cargo berths spanning a total length of 2, 205 m with depth alongside
of 11.4 m and capable of accommodating vessels up to 53, 000 displacement tonnes. An
area of 17.4 hectares near the operational area has been earmarked for development of a
commercial centre to enable shipping and other companies to set-up offices warehouses
and other facilities. The port handles various types of cargo including containerized
cargo, bulk cargo (dry & liquid) and break bulk. It has been privatised since 1998 and is
currently managed and operated by Kuantan Port Consortium Sdn Bhd. In the year 2006,
the port reportedly handled more than 10,650,000 tonnes of cargo.

The port allows the docking of large vessels and the lanthanides concentrate mined at
Mt. Weld, Western Australia can be economically shipped in large quantities to the port
in sea containers and enable Lynas to enjoy economies of scale and lower operating
costs. Warehousing facilities are also currently available for use at the port.

Kuantans proximity to the key export markets provides a significant freight advantage
and the landed cost per tonne of lanthanides via Kuantan is likely to be significantly
lower than the cost of shipping to and from Abu Dhabi. The proximity to the export
markets also minimises working capital impact of shipping and handling losses.

3-4

Airport
The nearest airport is the Sultan Ahmad Shah Airport, located 30 km south of GIE. The
airport is accessible via the main trunk road which is the Federal Route 3 which connects
Kuantan to Kuala Terengganu. The Kuala Lumpur International Airport (KLIA) which is
a main hub for air transportation in Asia Pacific is located in Sepang, State of Negeri
Sembilan approximately 250 km southeast of Kuantan.
Road Network
The Gebeng Industrial Estate (GIE) is linked to the major town of Kuantan and regional
port and airport by the main coastal trunk road, Jalan Kuantan-Kemaman (Federal Route
3) and the East Coast Highway. These links also provide access to the southern tip of
Johor Bahru whilst the East-West Highway to the north of the industrial area (North of
Terengganu) provides direct access to Penang, Ipoh and other major towns in the North-
West.

The East Coast Expressway (Phase 1) comprises a 169 km dual carriageway that
commences from the Karak Expressway and ends at the Pahang - Terengganu border
near Jabur. The construction of the East Coast Expressway began in 2000, and the Phase
1 stretch was opened to vehicles in August 2004.

The Gebeng Bypass is a new highway connecting Jabur, Terengganu to Gebeng which
was opened to traffic on December 2006.

All these roads have been designed for the movement of heavy vehicles transporting
industrial and oversized loads and are thus advantageous for the transport of raw
materials and finished products.

Rail Network
PETRONAS (Petroliam National Berhad) has constructed an industrial railroad which
links its oil refinery complex in Kerteh, Terengganu, with the petrochemical complex
within the GIE and the Port of Kuantan. The line is exclusively used to transport
petroleum products. The rail which runs some 77 km connects the industrial town of
Paka to Kuantan. Within the GIE, the rail terminal is located less than 1 km west of the
plant site. This railroad is a potential mode of transportation of raw materials and
finished products to and from the Port of Kuantan.

Natural Gas Supply
Natural gas and liquefied petroleum gas (LPG) supply is readily available from the
national supplier, Petronas Gas or Gas Malaysia via pipelines or tankers.

3-5

Power Supply
Tenaga Nasional Berhad (TNB) supplies power to the State of Pahang over a national
grid at 275 kV and 132 kV. The GIE obtains its power supply from the Tanjung Gelang
substation which generates power at a capacity of 2 x 15 MVA. Power supply is
available via the exiting TNB substation (intake station) located within the GIE less than
3 km south to the south of the project site.

Water Supply
The water supply network for Gebeng managed by the Pahang Water Supply Department
comprises a 32 MGD supply from the Semambu Water Treatment Plant, with 3
balancing reservoir at 4.5 MGD. There are also two other sources, namely the 2 MGD
and 1.5 MGD reservoirs at Bukit Penggorak, Gebeng, and 0.5 MGD and 1.0 MGD
reservoirs at Bukit Merah Gebeng. Currently the existing industries utilize about 12
MGD of water. There is a balance of 8 MGD water supply for the GIE.
The existing water supply resource is adequate for the process and potable water
requirements of the plant.

3.3.3 Availability of Local Suppliers

There are readily available chemical reagents manufacturers within the Teluk Kalong
Industrial Area in the neighbouring state of Terengganu, namely the Malay-Sino
Chemical Industries, Sen Sen Chemical, Petronas and Unichamp. Discussions are
presently ongoing with these Malaysian suppliers to ensure a steady and readily
available source of chemical reagents to meet the proposed plants requirements.

3.3.4 Availability of Skilled Workforce

The Gebeng Industrial Estate (GIE) is one of development components of the Sungai
Karang Development Planning Block under the Kuantan town plan. This block of 25,365
ha comprises Cendur, Cerating, Sungai Ular, Sungai Baging and Gebeng. The total
population in this area is 12,660. The town of Kuantan which is the capital of the State of
Pahang lies approximately 20 km to the southwest of the GIE. The town which covers an
area of 2,960 km
2
is made up of a total population of 394,500. It is bounded by Jerantut
to the north-east, Maran to the south-west and Pekan to the south-east. Kuantan is
bounded by Kemaman, Terengganu in the north-east direction. Based on the Kuantan
2015 Structure Plan published in December 2006, the population within the district is
about 12,660.

Due to proximity to the population centres, the proposed location in Gebeng provides
good access to essential and developed infrastructure facilities and also, pools of
experienced and qualified labour. In addition, Kuantan area remains an attractive
location for skilled labour force looking to relocate from the capital.

3-6

In addition, there are well established labour hire organisations which can provide the
labour required for the Gebeng project if necessary.

3.4 BUILD-OUT VERSUS NO-BUILD OPTIONS

3.4.1 Build-Out Options

The Build-Out option would entail the implementation of the proposed Advanced
Materials Plant within the GIE as proposed by Lynas. It is clearly evident that the
implementation of the project would accrue positive economic benefits to the State
Government and Lynas. Positive social and economic impacts to the local populace are
also predicted in the form of increased job opportunities, skills and hence a better quality
of living.

The potential concerns arising from the implementation of the project involve
environmental issues. In the event adequate mitigation measures are not incorporated in
the design and operation of the plant, the following potential environmental impacts are
envisaged:

Degradation of the Sg. Balok river water quality: As the proposed plant site is not
within a potable water catchment area, all discharges arising from the plant will be
required to comply with the less stringent Standard B discharge limits as required
under the Environmental Quality (Sewage and Industrial Effluent) Regulations, 1978.
Based on the plant design, treated effluent from the wastewater treatment plant will
be discharged into the stormwater retention pond on the plant site. From the pond,
the combined discharge will flow out into the external earth drain which runs along
the southern boundary of the site in a westerly direction into Sg. Balok. This
discharge will increase the pollutant loading in the river system. If the Standard B
limits are significantly breached the carrying capacity of the river will be affected.
Increased organic, suspended solids and chemical loading of the river will result in
adverse impacts to the general health of the river body. These impacts can be
minimised by ensuring effective wastewater treatment technological options are
given due consideration during the design phase.

Deterioration of Ambient Air Quality: The plant, its ancillary facilities and
operations are potential sources of air pollution. Sources of major, minor and fugitive
emissions arising from the plant operations will be evident during the operational
phase. The main sources of air emission from the operation of the plant will be the
waste gas treatment system and to a lesser extent the gas fired boilers and product
calciners. Suitable air control measures are necessary to ensure the concentration of
pollutants arising from these sources are within the regulatory limits and have
minimal adverse impacts on the people working and residing within the Zone of
Impact (5 km radius of the project site).

3-7

Increased Ambient Noise Levels: The operation of the plant is expected to increase
the ambient noise levels at the site and its immediate surrounding area. However, the
nearest sensitive receivers identified are Taman Balok Perdana and Taman Balok
Makmur about 3 km south of the site. They are located along the Kuantan-Pelabuhan
By-pass road, across the GIE. Thus, noise impacts to these residential areas are not
expected to be significant. However, in the absence of appropriate noise abatement
measures, the employees working within the plant boundary may be subjected to
increased occupational noise which may have potential adverse impacts as a result of
prolonged exposure. In designing the plant building structure, due importance must
be given for noise attenuation at the source to ensure the noise levels at the site
boundary are within the regulatory limits.

Potential Soil and Groundwater Contamination: The operation of the plant will
result in the generation of three major residue steams, namely the Water Leach
Purification Residue (WLP) from the cracking and separation process, the Flue Gas
Desulphurisation Residue (FGD) from the waste gas treatment system (scrubber) and
the Neutralisation Underflow Solids from the wastewater treatment process (NUF).
These waste streams have been classified as radiological wastes by the Atomic
Energy Licensing Board (AELB) and thus will be handled and stored in accordance
to the requirements of the Board. Lynas proposes to segregate and temporarily store
these wastes within engineered residue cells constructed within the plant site. The
design of these cells will be developed by Lynas and the EPCM Contractor Ranhill
Worley-Parsons in conjunction with the recommendations of the Malaysian Nuclear
Agency (MNA) which are based on the agencys Radiological Impact Assessment
carried out for the project. Storage of these residues within the site may be a potential
source of soil and groundwater contamination in the event of loss of integrity of the
residue storage cells and, inadequate provision of soil and groundwater protection
measures.

Storage of Hazardous Materials: Potential for contamination of land and water
resources exists due to the bulk storage of hazardous reagents including concentrated
acids. In mitigating such events, containment measures for such substances must be
in place. These measures should be designed to contain spills and leaks, preventing
them from escaping into the environment under normal operating conditions.

Chapter Five of this report provides detailed description of these impacts and the
recommended mitigation measures to ensure environmental protection and regulatory
compliance. It is the responsibility of the Project Proponent to give due consideration for
the environmental impacts highlighted in this study; and incorporate the recommended
mitigation measures into project planning and design.

3-8

3.4.2 No-Build Option

The construction and operation of the Advanced Materials Plant is expected to bring
about significant positive benefits to Lynas as the Project Proponent, the State
Government of Pahang, and the locals residing in the area as described in Section 1.7 in
Chapter 1 of this report. In the event the project does not go ahead and the plant is not
built on the proposed site, the benefits described in Section 1.7 will fail to materialise.

However, from an environmental perspective, the potential environmental concerns
described in the section above will cease to exist and there will be no change to the
prevailing environment condition.

3.5 RECOMMENDATION

The findings of this report will demonstrate that the predicted environmental impacts
arising from the operation of the Advanced Materials Plant can be effectively mitigated
and reduced to sustainable levels with the implementation of appropriate mitigation
measures. The findings will also show that there will be no detrimental or harmful
impacts which cannot be mitigated or, unavoidable. These measures will include
technologically sound practices and environmental best management practices and thus
any change in ambient air quality or river water quality will remain within regulatory
limits. Additionally, an Environmental Management Plan which includes periodical
environmental monitoring and audits for the construction and operational phases of the
project will be developed and implemented. This is to ensure that all recommendations
of this EIA and the requirements of the relevant government agencies are executed by
Lynas.

In considering the above, and the significant positive economic and social benefits of the
project to the local area of Gebeng, the state of Pahang and the country, the Consultants
recommend that the Build-Out Option be adopted.


4-1
CHAPTER FOUR
4.0 EXISTING ENVIRONMENT

4.1 INTRODUCTION

This section provides a description of the physio-chemical, biological and social
aspects of the environment within the Zone of Impact (ZOI), highlights the
components of environmental concern and establishes the baseline conditions prior to
the implementation of the Advanced Materials Plant within the Gebeng Industrial
Area, Kuantan, Pahang.

The ZOI is the term used to describe the area most likely to be impacted by the
implementation of the project. For the purpose of this study, the ZOI represents the
sector within a 5 km radius of the plant site. The information provided within this
chapter forms the basis of the impact assessment in Chapter Five.

The description is based on both primary and secondary data. Primary data was
obtained from field surveys and ad-hoc environmental monitoring programmes.
Secondary data was obtained from publications by the Department of Environment
(DOE), the Local Authority (Kuantan Municipal Council or Majlis Perbandaran
Kuantan), Department of Fisheries (Kuantan District), Department of Statistics
(Headquarters, Putrajaya), Alam Sekitar Malaysia (ASMA) and other relevant
government agencies. Information was also extracted from the Consultants in-house
database on the project area.

The ad-hoc environmental quality monitoring programme for ambient air, boundary
noise and surface water quality was undertaken by Environmental Science (M) Sdn.
Bhd, (SAMM No: 076). Soil and groundwater samples collected by ENVIRON from
seven bore wells within the site were analysed by ALS Technichem Sdn. Bhd.
(SAMM No: 147). Both laboratories are accredited by the Department of Standards
(DSM), Malaysia.

The area encompassed by the ZOI is presented in Exhibit 4.1a whilst the current and
planned landuses within the ZOI is presented in Exhibit 4.1b which was extracted
from the document entitled Kuantan 2015. The publication is the Kuantan District
Local Structure Plan (2004-2015) issued by the Kuantan Municipal Council. A
detailed description of the project site and its surroundings are presented in the
proceeding sections.


4-2

4.2 SITE SETTING

4.2.1 Project Site

The site earmarked for the establishment of the proposed Advanced Materials Plant is
a parcel of industrial land located centrally within the Phase III area of the Gebeng
Industrial Estate (GIE) in the Mukim of Sungai Karang, District of Kuantan, State of
Pahang. The site lies at approximately latitude 0400N, and longitude 10322E. The
total area of the site is 100 hectares.

The location of the site within the GIE is indicated in Exhibit 4.2. The main industrial
facilities operating within the GIE are Petronas MTBE-Polypropylene, BP Chemicals,
WR Grace, EASTMAN, Kaneka, Cryovac, Polyplastics Asia Pacific, BASF-Petronas
and PDH Plant among others.

Based on a site reconnaissance survey carried out at the site in early October 2007, the
proposed site was observed to be largely cleared and filled to the existing platform
level but speckled with sparse secondary vegetation and shrubbery. The land plots
adjoining the site to the northern and western boundaries of the site are overgrown
with a mix of secondary vegetation and remnant peat swamp vegetation. To the east is
cleared vacant industrial land and to the south of the site across the site is the
Polyplastics facility.

The site can be accessed via two turn-offs from the Gebeng Bypass heading towards
Jabur. The first turn-off is a dirt track that accesses the site directly from its north-
eastern boundary whilst the second is a main trunk road that leads into the GIE. This
road connects to another internal road that leads to the site.

The site layout is presented in Exhibit 4.3 and a photolog which describes the
physical characteristics of the site is presented in Exhibit 4.4. Notations (arrows) on
the location of the various settings of the site captured by the photos are also included
in Exhibit 4.3. The direction of the arrows corresponds with the direction in which the
photos were taken.

4-3

4.2.2 Topography

Regionally, the GIE is located on the Kemajuan Tanah Tanah Merah area where Bukit
Tanah Merah was flattened to construct the GIE. The GIE is located within the Sungai
Balok catchment. The catchment is low-lying and is predominantly swampy. The
estimated average land elevation is 7 m above mean sea level.

The hilly areas located within the ZOI include Bukit Balok which is located about 6
km southwest of the GIE at a height of 230 m above mean sea level (MSL). Bukit
Pangram which rises 197 m above MSL is located 7.5 km southeast of the industrial
estate. Sungai Balok flows 3 km west of area flowing in the southerly direction. The
nearest coastline is 3 km to the east.

A topographical survey of the site was carried out by Jurukur Teguh (Terengganu) in
October 2007. The survey details are provided in Exhibit 4.5. The regional
topographical setting is presented in Exhibit 4.1.

The topographical survey indicates that the site is relatively flat with an overall
natural gradient of 0. The ground levels at the site generally ranged between 7.4 m
and 7.8 m above MSL. There is a shallow earth trench that cuts across the site in a
south easterly direction. A second shallow earth trench bisects the site in a north-south
direction.

4.2.3 General Geology, Soil and Hydrogeology

Literature Review

Information regarding the general geology, soil and hydrogeology of the site and the
surrounding area was extracted from the following sources:

District Memoir 6: The Geology and Mineral Resources of the Neighbourhood
of Kuantan, Pahang (1952);
Geological Map of the Kuantan Sheet, Pahang in 1 : 63,360 scale (1951);
Geological Map of Peninsular Malaysia in 1 : 2,000,000 scale (8th Edition)
(1985);
Quaternary Geological Map of Peninsular Malaysia in 1 : 1,000,000 scale (1st
Edition) (1989);
Reconnaissance Soil Map of Peninsular Malaysia in 1 : 500,000 scale (1968);
and
Hydrogeological Map of Peninsular Malaysia in 1: 500,000 scale (1975).

4-4

The Reconnaissance Soil Map of Peninsular Malaysia indicates that surface soils at
the site and the surrounding areas are alluvial in nature and comprise mainly of peat.
A review of published geological memoirs and geological maps of the Kuantan area
revealed that geologically, the site and much of Mukim Sungai Karang are underlain
by alluvium up to a depth of approximately 115 feet (ft) or 38 meters (m). The general
area was swampy and had been deposited with soil debris brought down by rivers.
The Quaternary Geological Map further describes that this alluvial layer to consist of
peat, humic clay and silts of the Beruas and Simpang Formations.

Granite, reportedly formed in Cretaceous times, underlies the Quaternary Alluvium
layer. This granite intruded into both the older Lower Carboniferous strata and older
beds of the Arenaceous Series, and forms much of the bedrock underlying the GIE
with the most prominent outcrop at Bukit Pangram, about 3.0 km southeast of the site.
The granite is reportedly variable in composition and texture but is commonly
porphyritic, medium grained biotite.

Arenaceous sedimentary rocks are reported in the Bukit Balok area and at Tanjung
Gelang area approximately 6.0 km southwest and 7.5 km southeast from the site
respectively. The Arenaceous series predominantly consists of quartzite, grit and
conglomerate.

In addition, basaltic rocks were also observed at shallow depths in a few small areas
to the west and southwest near Sungai Balok. Reportedly, the basaltic magma rose,
mostly through fissures in the granite.

The geological map of the site and surrounding areas are presented in Exhibit 4.6.

The Hydrogeological Map of Peninsular Malaysia indicates that the unconsolidated
alluvial deposits in the general area have an estimated potential yield of between
4,000 and 6,000 gallons/hour/well.


4-5

Site Investigations

Geotechnical site investigations carried out at the proposed project site revealed that
subsurface conditions to be generally consistent with the information obtained from
published geological reports and maps. The subsurface of site can generally be
classified into the following:

Fill material;
Alluvium; and
Weathered bedrock.

The upper fill material across the site consists of Clayey Sandy Gravel and Clayey
Gravelly Sand, generally between 0.8 m and 1.8 m thick. Reportedly, the fill material
was sourced from a local borrow and placed approximately four years ago.

Alluvial deposits, with a thickness of up to about 35 m, underlie the fill layer across
the site. The alluvial deposits can be further subdivided into several sublayers. The
upper alluvial layer comprises very soft medium plasticity Organic Clay and Peat.
This layer has a thickness of about 0.6 m to 1.7 m, and contains partially decomposed
plant material. The Organic Clay generally grades into a green-brown soft Clay and
light grey loose Silty/Clayey Sand. Beneath this, alternating layers of Silty/Clayey
Sand, Sandy/Clayey Silt and Sandy Clay of variable thickness were observed across
the site.

Weathered bedrock and associated residual soils comprising hard Sandy Silt and
Sandy Clay were encountered at depths of around 35 m below ground surface (bgs).

At the time of site investigations, stabilized groundwater level observed at boreholes,
test pits and monitoring wells within the site were in the range of 0.95 to 3.5 m bgs.
The water table appears to coincide with the Organic Clay of the upper alluvial
deposits. Groundwater recharge at the site is anticipated to come almost entirely from
rainfall. Increased recharge can be expected during the wet monsoon period in
November and December. Field tests performed indicated that the hydraulic
conductivity of Organic Clay and the underlying Silty Sand to be in the range of 10
-7

10
-8
m/s and 10
-6
m/s respectively. More details are provided under Section 4.6.9 of
this chapter.


4-6

4.2.4 Water Resources

The GIE where the proposed plant site is to be located was formerly part of the the
Paya Tanah Merah peat swamp forest. Subsequently, when the GIE was developed,
the area was reclaimed using fill quarried from the nearby hilly areas. The two main
rivers that drain the GIE are Sungai Balok and Sungai Tunggak. Sg. Balok originates
as Sungai Batang Panjang from the hills to the northwest of GIE and generally serves
the western catchment of the GIE. Sungai Tunggak originates from the Tanah Merah
peat swamp forest and flows south along the eastern boundary of the GIE. which
generally drains the areas within the eastern sector of the site (Exhibit 4.7). The site is
within the Sungai Balok catchment.

All drainage from the proposed plant site will be discharged into Sungai Balok.

The tide for the Kuantan area is predominantly diurnal, with a tidal range of 2 m 3.5
m. Sungai Balok is likely to be tidal up to almost 10 km upstream of the river mouth.

Sungai Balok flows along the western boundary of GIE in a southerly direction before
its confluence into the coastal waters of the South China Sea. The primary source of
pollution into this river is the drainage discharge from the GIE at two locations along
the river channel.

Sunggai Tunggak which is a tributary of Sungai Balok flows serves the eastern
catchment of the GIE flows in a southerly direction before its confluence at Sungai
Balok.

No historical river flow data are available for Sungai Balok and Sungai Tunggak from
published records reviewed during the course of this study.

There are no impoundments for potable water supply within the catchments of Sungai
Balok and Sungai Tunggak.

A photolog of the Sungai Balok, its riparian areas and the two GIE drainage discharge
outlets are presented in Exhibit 4.8.


4-7

4.3 CLIMATE AND METEOROLOGY

The climate of Malaysia is equatorial characterized by fairly high but uniform
temperatures, high humidity and copious rainfall throughout the year with little
seasonal variation.

Rainfall distribution patterns over the country are affected by local topography and
wind directions. Based on predominant wind flow regimes, four periods can be
distinguished. The southwest monsoon is usually established in the later half of May
or early June and ends in September. The prevailing wind flow is generally south-
westerly and light. The northeast monsoon usually commences in early November and
ends in March. During this period, steady easterly or north-easterly winds blowing
from the South China Sea result in high precipitation, particularly to the east coast
region of Peninsula Malaysia. The months of April and October are transitional or
inter-monsoon periods and are characterized by variable wind conditions.

The nearest Malaysian Meteorological Service (MMS) station to the project site is
located at the Sultan Ahmad Shah (SAS) Airport in Kuantan, Pahang approximately
30 km southwest of the GIE. The station is located at latitude 3 47 N and longitude
103 13E at 15.3 m above MSL. As the airport is located 30 km southwest of GIE
and further inland (12 km compared to 2 km), small differences in the microclimate
are likely between the sites although the macroclimate is essentially the same. For
purposes of this study, climate and rainfall data was obtained from the station for the
period 1951 October 2007, while other meteorological data was obtained for the
period 1975 2006.

4.3.1 Wind Speed and Direction

The annual wind rose and a wind speed/direction distribution matrix for the Sultan
Ahmad Shah (SAS) Airport are presented in Exhibit 4.9.

On an annual basis prevailing winds are from the north (~ 26.5% of the time) and
southwest (~11.6% of the time). However, wind speeds are generally low occurring
below 3.3 m/s for 80.3% of the time and rarely exceeding 5.4 m/s (1.7%). Higher
wind speeds are typically associated with winds from the north, northeast, east and
southwest.

Exhibit 4.10 which presents the seasonal wind roses for the period 19752005 clearly
demonstrate the monsoonal wind regimes experienced between May and September
(SW Monsoon) and November to March (NE Monsoon). Variable wind conditions are
observed in the inter-monsoon periods in April and October.

4-8
Due to the close proximity of the proposed project site to the sea, the project site also
experiences the effects of diurnal wind patterns (land and sea breezes) typically
experienced at coastal locations.

4.3.2 Temperature

Temperature records for the period 19682007 showed fairly uniform temperatures
throughout the year, with mean monthly temperatures ranging from 25C in the
months of January and December to 27.3C in March. The slightly lower 24-hour
mean temperatures observed in the period of NovemberFebruary each year can be
attributed to the high precipitation and high cloud cover during the wet northeast
monsoon period. The mean annual temperature is averaged at 26.3 C.

The mean monthly temperature variation for the period 1968 to 2007 is graphically
illustrated in Exhibit 4.11.

4.3.3 Relative Humidity

The mean 24-hour relative humidity is also fairly high and constant throughout the
year typically ranging from 83.7% in the period between July and August to 89% in
the period between November and December. The average annual 24-hour relative
humidity is 85.2%.

Mean monthly relative humidity variation for the period 1968 to 2007 is graphically
illustrated in Exhibit 4.11.

4.3.4 Rainfall

The average annual rainfall recorded at the station over the period 19512007 is 2,958
mm with an average of 189 rainy days annually. The highest annual rainfall was
recorded in 1967 at 4,268 mm.

Although rainfall is heavy throughout the year, variations are evident. The wettest
months are October, November, December and January (NE Monsoon) with a
monthly average of 277 mm, 363 mm, 621 mm and 310 mm respectively. The highest
monthly rainfall was recorded in the month of December 2001 at 1,471 mm and the
lowest monthly rainfall was recorded in February 1998 at 1.2 mm. The average
monthly rainfall for the remaining months was in the range of 147 mm and 215 mm.

Summaries of average annual rainfall and the number of rainy days recorded at the
station are presented in Exhibit 4.12.

4-9

4.3.5 Seismology
Peninsular Malaysia is classified as a seismically stable area. It is not located within a
recognised earthquake zone although minor tremors may be felt on the west coast of
the peninsular from earthquakes that occur in neighbouring Sumatra, Indonesia.
According to records provided by the Seismology Division of the Meteorological
Department of Malaysia, the proposed project site is located in Zone III of Maximum
Observed Intensity based on the Modified Mercalli (MM) Scale of 1931. MM
Intensity Scale III is defined as:

Felt quite noticeably indoors, especially on upper floors of buildings,
but many people do not recognize it as an earthquake. Standing motor
cars may rock slightly. Vibration like passing truck.

4.4 LANDUSE WITHIN THE ZOI

4.4.1 Regional Landuse Pattern

A breakdown of the various landuse within a 5 km radius of the proposed advanced
materials plant site (ZOI) is presented in Table 4.1.


4-10

Table 4.1 Summary of Current Land Uses within the Zone of Impact (ZOI)

Land Use Radial
Distance from
the Centre of
the Site
North South East West

< 1 km

This area is within the site
boundary.

boundary.

boundary.

boundary.

1 km 3 km

Unoccupied industrial plots
overgrown with secondary
vegetation (part of the GIE).

The Gebeng Bypass (Jabur-
Cherating Link) is located to the
north of the site.

The Kuantan Port Kerteh railway
line runs along to the north east of
the site.

Polyplastics Asia Pacific Sdn Bhd
is located about 50 m across the
railway line and road from the
southern boundary of the site.

Unoccupied industrial plot (part of
the GIE) to the north-eastern
boundary of Polyplastics.

Unoccupied industrial plots (part
of the GIE) located to the south of
Polyplastics.

Industries operating south of
Polyplastics are a Biodiesel Plant,
Erupee Sugar, Kaneka, Flexsys,
Eastman, WR, Cryovac, BP
Chemicals and MTBE.

The Kuantan Port-Kerteh railway
line runs along the eastern
boundary of the site. This rail link
is presently not in use.

The Petronas gas pipe runs on line
to the east of the site.

overgrown to the east of the site,
across the railway line.

Undeveloped plots of land with the
GIE on the southeast side of the
site.

The Kuantan Port Kerteh railway
line runs along the railway
terminal located to the west of the
site.

The utilities reserve runs along the
railway line.

Gebeng Railway Terminal which
is part of the Kuantan Port-Kerteh
railway network is located to the
west of the site. This is presently
not in use.

overgrown with secondary
vegetation (part of the GIE).


4-11
Land Use Radial
Distance from
the Centre of
the Site
North South East West

1 km 3 km

Across the road from the Kuantan-
Pelabuhan Bypass are two
residential settlements, namely
Taman Balok Perdana and Taman
Balok Makmur.

To the south-west of the site is a
Petronas Emergency Response
Centre. To the west of the centre is
the BASF complex.

Sungai Balok flows 3 km to the
west in a southerly direction.

3 km 5 km

Secondary forests cover the areas
to the north and northwest of the
site.

Sporadic clusters of residential and
commercial properties are located
to the northeast along the coastal
road leading to Kuala Terengganu.

The Kuantan-Pelabuhan Bypass
runs 4 km south of the site.

Sungai Tunggak flows
approximately 5 km south of the
site.

Sporadic clusters of residential and
commercial properties are located
along the coastal road leading from
Kuantan to the Port.

The East-Coast Highway runs
about 4 km from the eastern
boundary of the site.

The Kuantan Port facilities lie
about 4.5 km to the south-east of
the site.

The Cherating Beach lies about 5
km east of the site.

Unoccupied industrial land
overgrown with peat swamp
vegetation is located to the west of
the site.


4-12

4.4.2 Gebeng Industrial Estate (GIE)
The GIE is one of the main industrial areas in Pahang is located approximately 35 km
north of the Kuantan town centre. The nearest airport is the Sultan Ahmad Shah
Airport, located 30 km south of GIE. Kuantan Port is located 4 km east of GIE. Both
the airport and the port are accessible via the main trunk road which is the Federal
Route 3 (connects Kuantan to Kuala Terengganu). The Phase 1 stretch of the East
Coast Expressway leads to the GIE.

The Pahang State Development Corporation (PASDEC) is responsible for the
management of the GIE. Discussion with PASDEC and review of historical
information indicates that construction of the estate commenced in 1982 with the
initial development of the Phase I area. Prior to development, the area consisted of a
mixture of low lying peat swamp forest, disturbed secondary forest and stretches of
rubber plantation belonging to the State Government and the PASDEC.

A forested hill was reportedly located towards the west of the Phase III area. The
Phase II area comprised mainly of the peat swamp, rubber plantation and stretches of
secondary re-growth. Some parts of the Phase II area were reportedly used as a
borrow area to provide fill for the Phase I development.

The total land area allocated for GIE is 9,600 acres. PASDEC developed the industrial
area in four phases (Phase I to IV). Details of various development stages are
summarised below in Table 4.2.

Table 4.2 Development Stages of the Gebeng Industrial Estate (GIE)

Phase I
Established in 1982 and located to the south of the Phase II development. The
development comprises an area of 700 acres and is fully occupied. The existing
industries include MTBE, Polypropylene, AMC, Demi Bintang, Choice Woods,
Hassan Milling, ATD, MEICO, Suasa Unik and Cargill Oil Palm.

Phase II Established in 1993 and covers an area of 1,400 acres. At present only 80% of total
area is occupied. The industries located here include BP Chemicals, Eastman, WR
Grace, Cryovac, Kaneka, Flexsys and Kontena Nasional.

Phase III Development commenced in 1997 and still expanding. Located northwest of the
Phase II development, it covers a development area of 2,500 acres. The present
occupants are BASF Petronas Chemicals, Petronas CUF, Petronas PDH and
Polyplastic.

Phase IV Presently undeveloped. It has total potential development area of 5,000 acres and
PASDEC has allocated 60% from this area for petrochemical industries.


4-13

These industries are mainly situated on the western, southern and eastern sections of
the GIE (see Exhibit 4.2). A photolog describing the surrounding industrial facilities
areas are presented in Exhibit 4.13.

Polyplastics Asia Pacific Sdn Bhd which is located 50 m south of the site is the
nearest industrial facility to the site.

4.5 HUMAN ENVIRONMENT

Residential settlements in the vicinity of the GIE are primarily located along the
existing road network.

The nearest human settlements to the project site are Taman Balok Perdana and
Taman Balok Makmur which is located about 3 km south of the site along the
Kuantan-Pelabuhan Bypass road.

Based on statistical data obtained during the most recent population census in 2000 by
the Department of Statistics Malaysia, the total population count for Taman Balok
Perdana, Taman Balok Makmur and Kem TLDM Kampung Seberang Balok is 5,973.
Of this population number, about 57% are 25 years and below. Eighty-seven percent
of the population comprise Malays, 0.2% of the population are Chinese, while 2.2%
of the population are Indians.

Other settlements neighbouring the site are Kampung Sungai Ular (2.5 km north of
Kampung Gebeng), Kampung Hulu Balok (3km south-east of the site), Kampung
Berahi (4.5 km south of the site), Kampung Seberang Balok (6 km south of the site).

South of Kampung Seberang Balok is Kampung Balok and Kampung Balok Baru.
These settlements comprise residential and commercial structures. The majority of the
areas are sparsely populated.

Other settlements include Kampung Gebeng (3 km north-east of the site) and
Kampung Selamat (4 km south-east of the site).


4-14

4.6 ENVIRONMENTAL BASELINE INVESTIGATION

Environmental baseline data was collected from the project site, its boundaries and at
the sensitive receivers during the period 29
th
October 01
st
November 2007.

The data collected represents the prevailing noise levels, ambient air quality, soil and
groundwater quality and the water quality of Sungai Balok. Riverbed sediments were
also collected and analysed for heavy metals, and plankton and macrobenthos
biodiversity.

The environmental samples were collected by Environmental Science Malaysia, an
analytical laboratory accredited by the Department of Standards, Malaysia.

The location of the environmental monitoring stations is presented in Exhibit 4.14.

4-15

4.6.1 Noise Measurements

4.6.1.1 Noise Monitoring Locations

Boundary noise levels were recorded at four (4) monitoring stations representing the
prevailing noise levels almost along the site boundaries. The description of the
monitoring locations is detailed in Table 4.3 below.

Table 4.3: Noise Monitoring Stations

Station No Location Description
Parameters
Monitored
N1 N0400.296
E10323.039
At an open space located at the south east
corner of the site.

N2 N0400.761
E10322.459
At an open space located at the north east
corner of the site.

N3 N0359.907
E10322.459
At an open space located at the south west
corner of the site.

N4 N0400.362
E10322.239
At an open space located at the west
quadrant of the site.

LAeq,
LA10,
LA90,
Lamax,
LAmin

4.6.1.2 Methodology

Noise monitoring was carried out using the ISO 1996 methodology. Noise
measurement was recorded using a pre-calibrated precision integrating noise meter
stationed at the selected monitoring stations. In recording the noise levels, the noise
meter was mounted on a tripod at a height of about 1.2 meter above ground level. The
microphone was provided with a wind shield throughout the measurement period to
prevent interference caused by wind. Standard acoustic principles and practices were
followed in the measurement of the noise data.

The noise meter was calibrated acoustically before using a Rion pistonphone (Model
NL 06) set at 250 Hz and 114 dB followed by electric calibration using the built-in
function mode. Noise measurement was made using the time weighting characteristic
of fast and A weighted decibel scale.

4-16

Noise data was recorded over a period of 24 hours at 15 minutes interval at each
monitoring station. The integrating noise meter which was set at the A-weighted
mode recorded noise level automatically every 2 seconds during the pre-set
measurement interval. The recorded noise level for each interval was systematically
and automatically integrated by the in-built electronic system. The integrated noise
levels in terms of LA
eq
, LA
max
, L
A5
, L
A10
, L
A50
, &L
A90
& L
A95
were then printed out.

4.6.1.3 Assessment of Results

The results obtained from the noise measurements at the four (4) monitoring locations
are graphically represented in the form of noise profiles (refer Exhibit 4.15(a) (d)).
The actual noise data recorded at these stations are presented in Appendix 2.

The noise levels are summarised and tabulated in Table 4.4.

The results of the noise monitoring programme are compared against the
recommended limits prescribed within Planning Guidelines for Environmental Noise
Limits and Control (2004) published by the Department of Environment (DOE) (see
Table 4.5).

Table 4.4: Summary of Noise Levels (LAeq (dBA))

Range of LAeq reading in
dBA
Percentage exceeded
Maximum
Permissible Sound
Level for
Location
monitored
Date
monitored
Day time Night time Day time Night time
*Maximum
Permissible Sound
Level in dBA
(1)

N1
30/10/07
31/10/07
35.7 58.3 47.3 53.5 0 0
N2
30/10/07
31/10/07
35.3 61.4 41.0 50.6 0 0
N3
29/10/07
30/10/07
40.2 63.8 39.4 51.5 0 0
N4
29/10/07
30/10/07
47.7 67.7 48.1 67.0 0 17
Daytime = 70
Night time = 60
(1): Maximum Permissible Sound Level (LAeq) for Designated Industrial Zones.

4-17

Table 4.5: Maximum Permissible Sound Level (L
Aeq
) by Receiving Landuse for
Planning and New Development

Receiving Land Use Category Day Time
(7.00 am 10.00 pm)
Night Time
(10.00 pm to 7.00 am)
Noise Sensitive Areas, Low Density
Residential, Institutional (School, Hospital),
Worship Areas

50 dBA 40 dBA
Suburban Residential (Medium Density) Area,
Public Spaces, Parks, Recreational Areas

55 dBA 45 dBA
Urban Residential (High Density) Areas,
Designated Mixed Development Areas
(Residential-Commercial)

60 dBA 50 dBA
Commercial Business Zones 65 dBA 55 dBA
Designated Industrial Zones 70 dBA 60 dBA

The LAeq readings at the three locations of the project site (N1, N2 and N3) were
lower than the maximum permissible sound level of 70 dBA for daytime and 60 dBA
for night time. The noise levels at N4 were compliant during the daytime but the night
time noise readings exceeded the limit of 60dBA 17% of the time.

It was noted that, nocturnal insect sounds and vehicular movement along the nearby
main road were among the noise sources observed at the monitoring locations. Table
4.6 describes some of the main noise sources at the four noise monitoring locations.

Table 4.6: Noise Sources at the Noise Monitoring Stations

Noise Sources
Location
Daytime Night time
N1 Noise from insects
Noise from nearby industrial
facilities
Vehicular movement
Noise from insects
Noise from nearby industrial
facilities
Vehicular movement
N2
N3
N4
Noise made by nocturnal insects
Vehicular movement
Noise made by nocturnal insects
Vehicular movement

4-18

4.6.2 Ambient Air Quality

4.6.2.1 Ambient Air Monitoring Locations

The location of the monitoring stations selected for the baseline ambient air quality
monitoring at the site is similar to the noise measurement locations. Description of the
monitoring locations is detailed in Table 4.7 below.

Table 4.7: Air Monitoring Stations

Station No Location Description
Parameters
Monitored
A1 N0400.552
E10322.976
At an open space located at the south east
corner of the site.

A2 N0400.740
E10322.416

At an open space located at the north east
corner of the site.

A3 N0400.740
E10322.416
At an open space located at the south west
corner of the site.

A4 N0400.267
E10322.279
At an open space located at the west
quadrant of the site.

TSP,
PM10,
NO
2
,
SO
2
,
H
2
SO
4
,
HF,
Acid mist

Ambient air quality at the identified monitoring locations were analysed for Total
Suspended Particulates (TSP), Particulate Matter (PM
10
), sulphur dioxide (SO
2
) and
nitrogen dioxide (NO
2
). These are the primary ambient air quality pollution
indicators.

4.6.2.2 Methodology

An automatic wind sensor (propeller type) and wind translator were used to record
wind direction and velocity. The propeller was set up at a pole. This was to ensure
that the measurement taken had good exposure of the instrument to the ambient wind.
To obtain the best accuracy orientation of the sensor to true north was carried out
using a prismatic compass. Recording was made for a period of twenty-four (24)
hours continuously.

4-19

Total Suspended Particulate in Ambient Air (ASTM D4096, 1993)

A high volume sampler was used to collect total suspended particulate samples for a
continuous period of 24 hours at the monitoring locations. The filtration medium was
pre-dried in an oven and transferred to a desiccator to maintain its constant weight.
After weighing, the filtration medium was sealed and to be used during fieldwork.

During sampling, the filter was loaded into the filter holder of the high volume
sampler. Air was sampled and drawn through the filtration medium by using a pump.
Total suspended particulate in the air was detained by the filtration medium. The
volume of air sampled was recorded automatically.

Particular Matter 10 Micron in Ambient Air (ASTM D4096, 1993)

A pre-calibrated PM
10
high volume sampler was used to collect particulate matter
measuring 1- micron and less for continuous period of 24 hours. The atmospheric
particulate matter as PM
10
is based on selection of PM
10
particles by internal
separation, followed by filtration and gravimetric determination of the PM
10
mass on
the filter substrate. The volume of air sampled was recorded automatically by the high
volume sampling system. Filtration medium preparation for PM
10
is the same as for
total particulate matter.

Nitrogen Dioxide Content in the Ambient Air (ASTM D 1607, 1991)

Nitrogen dioxide (NO
2
) in the ambient air was absorbed by aspirating a measured
volume of air through an azo-dye forming reagent in a gas washing bottle along the
sampling train. The sampling flow rate used was 200 ml/min for a period of one (1)
hours. The NO
2
present reacts with the azo-dye forming reagent to produce a colour
complex. The colour intensity was measured at 550 nm using UV-Visible
spectrophotometer.

Sulphur Dioxide Content in the Ambient Air (ASTM D 2914, 1993)

Sulphur dioxide (SO
2
) in the ambient air was absorbed by aspirating a measured
volume of air through a tetrachloromercurate (TCM) solution. The sampling flow
rate used was 200 ml/min for a period of twenty four (24) hours. SO
2
in the sample
reacted with the TCM solution to form a dichlorosulfonatomercurate complex.
EDTA was added to this solution to complex heavy metals that might interfere with
the measurement.


4-20

The collected sample was treated with a solution of sulfamic acid to destroy the
nitrite anion formed. It was then treated with a solution of formaldehyde and
specially purified acid-bleached pararosaniline containing phosphoric acid to control
pH. The reaction gave an intensely coloured solution, which was measured at 548
nm using UV-Visible spectrophotometer.

Sulphuric Acid (H
2
SO
4
) and Hydrogen Fluoride (HF) in the Ambient Air
(Adopted from NIOSH 7903, 1994)

Sampling of H
2
SO
4
and HF are carried out by using washed silica gel sorbent tube
coupled with tri-gas sampler. The ends of the sorbent tube are broken just before
sampling and the sorbent tube containing acid treated silica gel (silica gel 400 mg /
200 mg) is connected to the inlet of a tri-gas sampler. The suction pump of the tri-gas
sampler draws the ambient air sample at a flow rate of not more than 0.5 liter per
minute. As the air sample passes through the sorbent material an inorganic acid gas
present in the air sample is detained.

At the end of the sampling period, the loaded sorbent tube is collected, capped at both
ends and sent to the laboratory. After breaking the sorbent tube, the sorbent is
transferred to a 15 ml graduated centrifuge tube. 6 ml of eluent (bicarbonate/carbonate
buffer solution) is then added to the centrifuge tube. For 10 minutes, they are heated
in a boiling bath and then cooled before topping it up to 10 ml with eluent. H
2
SO
4
and
HF present are to be analysed using ion chromatograph. The concentration of the acid
gases in the ambient air is calculated based on the amount of acid detected versus the
volume of air sampled

Acid Mist in the Ambient Air (Adopted from NIOSH 7903, 1994)

Acid mist in the air was absorbed by aspirating a measured volume of air through
an absorbing solution in a gas washing bottle along the sampling train. For a period
of eight (8) hours the sampling flow rate used was 200 ml/min. Acid-base titration
method was used with pH as an indicator to analyse the concentration of acid mist
in the absorbing solution. The concentration of acids mist in the absorbing solution
was calculated and expressed in terms of H
2
SO
4
in air. This was calculated based
on the amount of H
2
SO
4
detected versus the volume of air sampled (JIS K 10106,
modified).

4-21


Concentrations of total suspended particulates, particulate matter (10m) and
gaseous pollutants in the ambient air at the four (4) monitoring stations are
summarised in Table 4.8 below. The actual wind data recorded at these stations are
presented in Appendix 2.

Table 4.8: Ambient Air Quality Monitoring Results

Results (g/m
3
)
Parameter Tested
A1 A2 A3 A4 RMAQG
Total Suspended
Particulate (TSP)
20 23 33 30
260 g/m
3

(24 hours averaging time)
Particulate Matter 10m
(PM10)
11 14 15 16
150 g/m
3

Sulphur Dioxide
as SO
2

<5 <5 <5 <5
105 g/m
3

Nitrogen Dioxide
as NO
2

<5 94 69 <5
320 g/m
3

(1 hour averaging time)
Sulphuric Acid
as H
2
SO
4

<10 33 <10 <10 -
Hydrogen Fluoride
as HF
<10 <10 <10 <10 -
Acid Mist -
RMAQG: Recommended Malaysian Air Quality Guidelines

4-22

The results obtained above are compared against the Recommended Malaysian Air
Quality Guidelines (RMAQG). The complete list of air quality parameters prescribed
within the RMAQG is presented in Table 4.9. The limits stipulated by the World
Health Organisation (WH0) (2005) are also presented for comparison.

Table 4.9: Ambient Air Quality Criteria

Pollutant Averaging
Time
Malaysian Air Quality
Guidelines
WHO (2005)
ppm g/m
3
g/m
3

1 hr

0.13 350 Sulphur dioxide (SO
2
)
24 hrs

0.04 105 20
24 hrs

150 50 PM
10
1 year

50 20
TSP

24 hrs 260 -
1hr

0.17 320 200
24 hrs

-
Nitrogen dioxide (NO
2
)
1 year

0.04 90 40
1 hr

30.00 35 mg/ m
3
Carbon Monoxide (CO)
8 hrs

9.00 10 mg/ m
3

1 hr

0.10 200 - Ozone (O
3
)
8 hrs

0.06 120 100
Lead (Pb) 3 months

1.5 1.5


4-23

The air quality data obtained showed that the 24-hours averaging concentrations of
total suspended solids (TSS) at all four (4) monitoring locations ranged from 20
g/m
3
to 33 g/m
3
while the 24-hours averaging concentrations of PM
10
varied
from 11 g/m
3
to 16 g/m
3
. These concentrations were very well below the limit
prescribed in the RMAQG at 260 g/m
3
and 150 g/m
3
respectively for TSS and
PM
10
.

Monitoring of gaseous sulphur dioxide (SO
2
) and nitrogen dioxide (NO
2
) showed
that concentrations of these gases were below their respective detection limits of 5
g/m
3
at all stations except for NO
2
at A2 (94 g/m
3
) and A3 (94 g/m
3
). SO
2
has a
24-hours averaging concentration limit of 105 g/m
3
while NO
2
has a 1-hour
averaging concentration limit of 320 g/m
3

The acid gaseous monitored, sulphuric acid (as H
2
SO
4
) and hydrogen fluoride (HF)
were below their detection limit of 10 ug/m
3
at all stations except station A2 which
recorded H
2
SO
4
concentration of 33 ug/m
3
.

Concentration of TSP, PM
10
, SO
2
and

NO
2
obtained at all the sampling locations
during this sampling exercise complied with their respective limits prescribed in
the RMAQG.

Based on metrological data on annual wind speeds, prevailing winds are from the
north 25% of the time. This indicates that the sensitive receivers are upwind of the
project site.

4-24

4.6.3 Wind Monitoring

4.6.3.1 Wind Monitoring Location

Wind monitoring was recorded at one (1) monitoring station within the project site.
The details of this monitoring location and the parameters monitored are presented in
Table 4.10 below.

Table 4.10: Wind Monitoring Stations

Monitoring
Station
Description
Parameters
Monitored
WD1 At an open space, at the northern sector of the site.

[N04 00.632 E103 22.872]

Speed and Direction

4.6.3.2 Methodology

An automatic wind sensor (propeller type) and wind translator were used to record
wind direction and velocity. The propeller was set up at a pole. This was to ensure
that the measurement taken had good exposure of the instrument to the ambient wind.
To obtain the best accuracy orientation of the sensor to true north was carried out
using a prismatic compass. Recording was made for a period of twenty-four (24)
hours continuously.


Percentage frequency of various wind direction and speed is tabulated in Table 4.11,
while the summary of wind direction and speed is summarised in Table 4.12. The
actual wind data recorded at these stations are presented in Appendix 2.


4-25

Table 4.11: Summary of Percentage Frequency of Various Direction and Speed

Point WD 1 (30/10/2007 - 31/10/2007)
<0.3 0.3 - 1.5 1.5 - 3.3 3.3 - 5.4 5.4 - 7.9 7.9 - 10.7 >10.7 Total
Calm 8.3 - - - - - - 8.3
N - 3.1 2.1 4.2 1.0 0.0 0.0 10.4
NNE - 1.0 1.0 2.1 1.0 0.0 0.0 5.2
NE - 1.0 1.0 0.0 0.0 0.0 0.0 2.1
ENE - 0.0 0.0 0.0 0.0 0.0 0.0 0.0
E - 1.0 0.0 0.0 0.0 0.0 0.0 1.0
ESE - 0.0 0.0 0.0 0.0 0.0 0.0 0.0
SE - 0.0 0.0 0.0 0.0 0.0 0.0 0.0
SSE - 0.0 0.0 0.0 0.0 0.0 0.0 0.0
S - 0.0 0.0 0.0 0.0 0.0 0.0 0.0
SSW - 0.0 0.0 0.0 0.0 0.0 0.0 0.0
SW - 0.0 0.0 0.0 0.0 0.0 0.0 0.0
WSW - 1.0 1.0 0.0 0.0 0.0 0.0 2.1
W - 3.1 3.1 4.2 0.0 0.0 0.0 10.4
WNW - 17.7 5.2 1.0 0.0 0.0 0.0 24.0
NW - 7.3 11.5 2.1 1.0 0.0 0.0 21.9
NNW - 7.3 2.1 3.1 2.1 0.0 0.0 14.6
Total 8.3 42.7 27.1 16.7 5.2 0.0 0.0 100.0

Table 4.12: Summary of Wind Direction & Speed

Period (LT)
(30/10/2007
31/10/2007)
1525 to
1910 hrs
1925 to
0010 hrs
0025 to
0710 hrs
0725 to
1510 hrs
Speed (m/s) 3.28 6.29 1.07 3.76 0.00 2.54 0.00 4.11
Predominant Direction N, NNW, NW NNW, N NW WNW, NW WNW, NNW

It is seen that over the two days, 42.7% of the time, the wind speed was between
0.3m/s 1.5m/s. It is also noted that 24.0% during the monitoring time, the wind was
in the west-northwest direction.

However, this ad-hoc 24-hours monitoring at one station within the proposed site
location is only representative of the wind conditions at the time of air quality
monitoring and does not represent the average wind condition at the site. Annual
metrological data from the Department of Metrology would be more accurate and
representative.

4-26

4.6.4 Water Quality

4.6.4.1 Water Sampling Stations

A total of seven (7) water samples were collected from Sungai Balok using the grab
sampling technique. The details of these locations are presented in Table 4.13.

As Sungai Balok is subject to tidal influence, water quality samples were collected
during both the high and low tide cycles. At each sampling location, three (3) samples
were collected and mixed in a single container. From this storage container, one
sample was drawn out, representing a composite sample for analysis. At each
sampling location, the three samples were collected from the surface, mid-depth and
slightly above the seabed.

Sample W1 was collected from the river mouth of Sungai Balok as it represents the
water quality of the river close to its estuary. Sample W2 was collected 100 m
downstream of confluence of Sungai Tunggak.

Sample W3 sample was collected 100 m downstream of the first drainage outlet from
the GIE. Station whilst sample W4 was collected 100 m downstream of the second
drainage outlet of the GIE. The fifth sample (W5) was collected 100 m upstream of
the second drainage outlet.

The W6 sample represents the water quality of the river 100 m downstream of the
proposed Lynas discharge outlet.

Station W7 was collected approximately 100 m upstream of the road bridge on the
Gebeng Bypass road.

4-27

Table 4.13: Water Quality Monitoring Stations

Station Description
Parameters
Monitored
W1 Water sample collected from the river mouth of Sungai Balok.
[N 03
0
56.468; E 103
0
22.383]

W2 Water sample collected 100 m downstream of the confluence of Sungai
Tunggak.
[N 03
0
56.700; E 103
0
22.331]

W3 Water sample was collected 100 m downstream of the first drainage
outlet (from the GIE).
[N 03
0
57.552; E 103
0
21.801]

W4 Water sample collected 100 m downstream of the second drainage outlet
(from the GIE).
[N 03
0
57.872; E 103
0
21.890]

W5 Water sample collected 100 m upstream of the second drainage outlet
(from the GIE).
[N 03
0
58.192; E 103
0
21.687]

W6 Water sample collected 100 m downstream of the proposed Lynas
discharge outlet.
[N 03
0
59.534; E 103
0
21.472]

W7 Water sample collected 100 m upstream of the road bridge (across the
Gebeng Bypass road).
[N 04
0
00.381; E 103
0
21.107]

pH
Temperature
DO
Total Coliform
Conductivity
BOD
COD
TSS
Hg
Cd
Cr
6+

As
CN
Pb
Cr
3+
Cu
Mn
Ni
Sn
Zn
Free Cl
2
S
2-
O&G
NH
3
TDS
Ca
Mg
Ag
Ba
Carbonate

4.6.4.2 Methodology

The samples collected were preserved and sent back to the laboratory for chemical
analysis. A summary of the parameters analyzed and the analytical methods used for
these water samples is provided in Table 4.14.

4-28

Table 4.14: Method of Chemical Analysis

Parameters Method
pH value APHA 4500-H
+
B, 1995
Biochemical Oxygen Demand @ 5 days at 20 C
(BOD)
APHA 5210 B, 1995/APHA 4500 O G, 1995
Chemical Oxygen Demand (COD) APHA 5220 B, 1995
Total Suspended Solids (TSS) APHA 2540 D, 1995
Mercury as Hg USEPA 245.1, 1991
Cadmium as Cd APHA 3111 B, 1995
Chromium Hexavalent as Cr
6+
APHA 3500-Cr D, 1995
Arsenic as As IH-PE: B3505: As, 1994
Cyanide as CN APHA 4500-CN C&F, 1995
Lead as Pb APHA 3111 B, 1995
Chromium Trivalent as Cr
3+
APHA 3111 B, 1995/APHA 3500-Cr D, 1995
Copper as Cu APHA 3111 B, 1995
Manganese as Mn APHA 3111 B, 1995
Nickel as Ni APHA 3111 B, 1995
Tin as Sn IH-PE: B3505: Sn, 1994
Zinc as Zn APHA 3111B, 1995
Free Chlorine as C1
2
IH-BS 1427, 1962
Sulphide as S
2-
APHA 4500 S
2-
F, 1995
Oil and Grease APHA 5520 B, 1995
Ammoniacal Nitrogen APHA 4500-NH
3
B&C, 1992
Temperature

APHA 2550 B, 1995
Dissolved Oxygen APHA 4500-O G, 1995
Conductivity APHA 2510 B, 1995
Total Dissolves Solids APHA 2540 C, 1995
Total Coliform ISO 9308-1
Calcium as Ca APHA 3111 B, 1995
Magnesium as Mg APHA 3111 B, 1995
Silver as Ag APHA 3111 B, 1995
Barium as Ba APHA 3111 D, 1995
Carbonate as CO
3
APHA 2320B, 1995
US-EPA: Environmental Monitoring Systems, Laboratory Office of Research and Development, United
States Environment Protection Agency.
APHA: Standard Methods for Examination of Water and Wastewater (1995), American Water Works
Association and American Public Health Association.
IH: In-House Method (approved by the Department of Standards, Malaysia)
ISO: International Standard, International Standard Orgnanization for Standardization, 1990.\

4-29

In-situ measurements were recorded at the site during sampling using a portable meter
at mid-depth. Physical measurements recorded include temperature, pH, dissolved
oxygen and conductivity.


The results of the water quality analysis are compared against the Interim National
Water Quality Standards (INWQS) which is used to classify rivers in Malaysia. The
data was compared against and Class III of the standards which apply to river bodies
not used for the abstraction of potable supply (unless extensive treatment is carried
out) but suitable for fisheries. A general comparison was also made against Class II of
the standards which requires conventional treatment for water supply, suitable water
quality for sensitive aquatic species and also suitable for recreational use with body
contact.

A description of some of the critical water quality parameters is provided below.

The conductivity of a solution is related to the concentration of ionised substances
present in the solution, temperature and sum of conductance of individual ions, both
positive and negative. Salinity refers to the concentration of dissolved salts, and is
normally stable in marine and coastal waters, but differs both vertically and
horizontally in estuarine waters.

Total Suspended Solids (TSS) comprises organic and mineral particles that are
transported in the water column. The presence of TSS in high concentrations within a
river body denotes land-based erosion occurring within the catchment area as a result
of anthropogenic activities. It is also linked to the transport of nutrients (especially
phosphorus), metals and a wide range of industrial and agricultural chemicals.

Dissolved oxygen (DO) is a vital component of a river system. Degradation of DO
levels will result in serious impediment to the biological activities of the riverbody.
High DO levels indicate low organic loading and conversely low DO indicates high
organic loading. If the organic load of a river system exceeds its carrying capacity, the
river becomes anoxic and anaerobic processes will dominate, emitting foul odours and
discolouring the river body. Subsequently the life of the river body deteriorates.

Biochemical Oxygen Demand (BOD) is typically used as a measurement of organic
loading of a natural watercourse. High BOD levels denote the presence of
decomposing organic matter (organic pollution) and these high levels normally
correspond with low DO levels; as DO is utilised by aerobic bacteria.

4-30

The presence of non-biodegradable matter in a watercourse is measured by
concentration of the Chemical Oxygen Demand (COD). High COD levels indicate
heavy loading of non-organic origin (non-biodegradable) and thus can be used as an
indicator of chemical pollution.

The presence of excessive nutrients (ammoniacal nitrogen (AN) and phosphorus) will
lead to increased biological activities, such as eutrophication which results in
decreased DO values. Eutrophication impedes the regeneration of the benthic
organisms and the quality of the river ecosystem by reducing the mortality of other
aquatic organism such as fishes, crustacean, etc. Typical sources of these nutrients
include agricultural run-off containing organic fertilisers, animal husbandry activities
and chemical pesticides/fertilisers.

pH is the expression of the molar concentration of the hydrogen ion as its negative
logarithm. It is one of the primary indicators to evaluate surface water quality and
suitability for beneficial water uses. Most natural waters have a pH value between 5.0
and 8.5 and seawater has pH values typically in the range of pH 8.0 and 8.5.

River Samples Collected During High Tide

The four river water samples (W1, W5, W6 and W7) collected during high-tide had
pH values ranging from 6.66 to 6.98 and dissolved oxygen (DO) levels ranging
between 3.52 mg/l and 4.23 mg/l. All the pH values and DO levels recorded were
well within the Class III range limit of 5 to 9 (pH) and 3.0 mg/l to 5.0 mg/l (DO). pH
values complied with Class II range limit of 6 to 9 but did not comply with DO limits
of 5.0 mg/l to 7.0 mg/l.

Concentrations of Biochemical Oxygen Demand (BOD), Total Suspended Solids
(TSS), total coliform and ammoniacal nitrogen (AN) recorded for samples were
lower than their respective Class III limits except for AN in sample W5 which
recorded at 2.2 mg/l and was higher than the Class III limit of 0.9 mg/l for AN. BOD,
TSS and Total Coliform also complied with Class II at all locations. However, only
W1 complied with Class II AN limit of 0.3 mg/l while the other three stations were
between 0.7 2.2 mg/l.

Chemical Oxygen Demand (COD) concentrations for these water samples were
slightly higher than the Class III limit (50 mg/l) except for sample W5 which
recorded 50 mg/l. All four locations exceeded the Class II limit of 25 mg/l with
levels of 50 59 mg/l.


4-31

No traces of cyanide, free chlorine, or oil and grease were detected in the samples
analysed. Sulphide was detected in all samples with readings ranging from 0.1 mg/l
to 0.4 mg/l except for sample W1 which was not detected.

The heavy metals analysed, i.e.Hg, Cd, Cr
6+
, As, Pb, Cr
3+
, Cu, Mn, Ni, Sn, Zn, Ag
and Ba, were either not detected or found in trace levels in all the samples. Among
the heavy metals detected were lead (Pb), manganese (Mn), zinc (Zn), nickel (Ni)
and Barium (Ba). Barium was detected in all samples with concentrations ranging
between 0.01 mg/l to 0.03 mg/l. Manganese, nickel and zinc were detected in
samples W5, W6 and W7 with readings ranging from 0.021 mg/l to 0.033 mg/l (Mn),
0.008 mg/l to 0.011 mg/l (Ni) and 0.012 mg/l to 0.052 mg/l (Zn). Readings of
manganese, nickel and zinc were well below the Class III limits.

Readings of conductivity and total dissolved solids of the water samples were in the
range of 29 us/cm to 19740 us/cm (conductivity) and 28 mg/l to 12990 mg/l (TDS)
respectively, while calcium (Ca) and magnesium (Mg) concentrations were recorded
in the range of 2.78 mg/l to 117 (Ca) and 0.71 mg/l to 384 mg/l (Mg), respectively.
Carbonate (CO
3
) was not detected in all these samples.

The W2 sample recorded a pH value of 7.14 and DO reading of 3.81 mg/l, both well
within the Class III range limit. pH level also complied with the Class II limit but DO
exceeded Class II limit of 5.0 mg/l to 7.0 mg/l. Concentrations of BOD, TSS,
ammoniacal nitrogen and counts of Total Coliform recorded for this water samples
were lower than their respectively Class III limits as well as Class II limits. The COD
concentration was 51 mg/l, marginally higher than the Class III limits of 50 mg/l and
much higher than the Class II limit of 25 mg/l. Readings of conductivity,
concentration of TDS, Ca and Mg recorded were 15720 us/cm (conductivity), 9670
mg/l (TDS), 89 mg/l (Ca) and 305 mg/l (Mg). Carbonate (CO
3
) was not detected in
this sample. Results for the rest of the parameters tested were either not detected or
detected below their respective Class III limits

The two water samples (W3 and W4) collected downstream of the first and second
drainage outlets respectively had pH values of 6.71 (W3) and 6.53 (W4), and DO
readings of 3.08 mg/l (W3) and 2.17 mg/l (W4). Both the pH and DO readings were
well within the Class III range limit. The pH value was also within the Class II limit
but exceeded the DO limit of 5.0 mg/l to 7.0 mg/l. Concentrations of BOD, COD,
TSS, and counts of Total Coliform recorded for these two water samples were lower
than their respective Class III limits for both the water samples collected. BOD, TSS
and Total Coliform were also within their respective Class II limits. COD levels were
46 mg/l (W3) and 34 mg/l (W4), exceeding the Class II limit of 25 mg/l.


4-32

Ammoniacal nitrogen readings recorded at 2.2 mg/l (W3) and 17.8 mg/l (W4) were
higher than the Class III limit of 0.9 mg/l. Readings of conductivity, TDS, Ca and Mg
for W3 and W4 were recorded at 1102 us/cm and 5300 us/cm (conductivity), 671
mg/l and 3570 mg/l (TDS), 12.4 mg/l and 15.2 (Ca), and 25.8 mg/l and 39.4 mg/l
(Mg) respectively. Carbonate (CO
3
) was not traced in these two samples. Results for
the rest of the parameters tested were either not detected or detected below their
respective Class III limits

The analytical results obtained for the samples collected at W1, W2, W3, W4, W5, S6
and W7 during high tide are presented in Table 4.15 below while the complete
laboratory results are attached in Appendix 2.


4-33

Table 4.15: Water Quality Results (W1, W2, W3, W4, W5, W6 & W7) (High Tide)

Results
Parameters Unit
W1 W2 W4 W5 W6 W7
Class III Class II
pH value - 6.98 7.14 6.53 6.89 6.76 6.66 5 9 6 9
Biochemical Oxygen Demand mg/l <2 <2 <2 <2 <2 <2 6 3
@ 5 days at 20 C
Chemical Oxygen Demand mg/l 52 51 34 50 59 54 50 25
Total Suspended Solids mg/l 5 4 <2 3 3 2 150 50
Mercury as Hg mg/l <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.004 0.001
Cadmium as Cd mg/l <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 0.01 0.01
6+
mg/l <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 1.4 0.01
Arsenic as As mg/l <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 0.40 0.05
Cyanide as CN mg/l <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 0.06 0.02
Lead as Pb mg/l <0.01 <0.01 <0.01 <0.01 0.01 0.01 0.02 0.05
3+
mg/l <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 2.50 -
Copper as Cu mg/l <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 - 0.02
Manganese as Mn mg/l <0.001 <0.001 <0.001 0.033 0.027 0.021 0.10 0.1
Nickel as Ni mg/l <0.005 <0.005 <0.005 0.011 0.008 0.011
0.90 0.05
Tin as Sn mg/l
<0.004 <0.004
<0.004 <0.004 <0.004 <0.004
0.004 -
Zinc as Zn mg/l <0.005 <0.005 <0.005 0.015 0.052 0.012 0.4 5

4-34
Results
Parameters Unit
W1 W2 W4 W5 W6 W7
Class III Class II
Free Chlorine as C1
2

mg/l
<0.01 <0.01
<0.01 <0.01 <0.01 <0.01
- N/A
Sulphide as S
2-
mg/l
<0.05 <0.05
0.20 0.20 0.40 0.10
- 0.05
Oil and Grease mg/l ND(<1) ND(<1) ND(<1) ND(<1) ND(<1)
Free from visible
layer,
discoloration,
deposits
Free from visible
layer,
discoloration,
deposits
Ammoniacal Nitrogen as AN mg/l
0.2 0.1
17.8 2.2 0.7 0.8
0.9 0.3
Temperature C
29.2 29.5
30.8 30.1 28.3 29.5
Normal 2 Normal 2
Dissolved Oxygen
mg/l 4.23 3.81 2.17 3.52 3.52 3.71 3 5 5 7
Conductivity us/cm
19740 15720
5300 270 655 29
- 1000
Total Dissolved Solids mg/l
12990 9670
3570 190 377 28
- 1000
Total Coliform Count/100ml
300 700
2100 600 800 300
50000 5000
Calcium as Ca mg/l
117 89
15.2 3.52 6.83 2.78
- -
Magnesium as Mg mg/l
384 305
39.4 2.63 9.95 0.71
- -
Silver as Ag mg/l
<0.005 <0.005
<0.005 <0.005 <0.005 <0.005
0.0002 0.05
Barium as Ba mg/l
0.01 <0.01
<0.01 0.03 0.02 0.02
- 1
Carbonate as CO
3
mg/l
<1 <1
<1 <1 <1 <1
-
Note:
1. Parameter limits of Class III under the DOE Proposed Interim National Water Quality Standards for Malaysia.
2. ND means not detected.

4-35

River Samples Collected During Low Tide

All the pH values and DO levels of samples W1, W5, W6 and W7 collected well
within the Class III range of 5 to 9 (pH) and 3.0 mg/l to 5.0 mg/l (DO). All stations
also complied with Class II pH limit of 6 to 9 but did not comply with the DO limit
of 5.0 mg/l to 7.0 mg/l. The readings ranged between 3.60 mg/l to 4.12 mg/l.

Concentrations of Biochemical Oxygen Demand (BOD), Total Suspended Solids
(TSS), total coliform and ammoniacal nitrogen (AN) recorded for all the water
samples were lower than their respective Class III limits. BOD, TSS and total
coliform concentrations complied with their respective Class II limits. AN levels
were between 0.5 mg/l to 0.7 mg/l exceeding the Class II limit of 0.3 mg/l by a small
difference.

Chemical Oxygen Demand (COD) concentrations for these water samples which
were recorded ranging between of 54 mg/l to 55 mg/l were slightly higher than Class
III limit (50 mg/l) except for sample W7 which recorded at 48 mg/l which was below
the said limit. All samples exceeded the Class II limit of 25 mg/l.

No traces of cyanide, free chlorine, or oil and grease were detected in these samples
analysed while sulphide was present in most samples with readings ranging from 0.2
mg/l to 0.4 mg/l except for sample W1 which was not detected.

As for the heavy metals analysed, they are either not detected or found only in trace
levels. Among the heavy metal detected were copper (Cu), manganese (Mn), zinc
(Zn), nickel (Ni) and Barium (Ba). Barium, manganese and nickel were detected in
samples W5, W6 and W7 with concentrations ranging between 0.02 mg/l to 0.05
mg/l (Ba), 0.019 mg/l to 0.030 mg/l (Mn) and 0.006 mg/l to 0.011 mg/l (Ni). Copper
was traced in samples W5 and W6 with readings of 0.014 mg/l and 0.005 mg/l
respectively. Readings of manganese, nickel and zinc were well below the Class III
limits.

Conductivity was recorded at ranging from 27 us/cm to 10450 us/cm, and total
dissolved solids of the water samples were in the range of 36 mg/l to 6182 mg/l.
Calcium (Ca) and magnesium (Mg) concentrations were recorded in the range of
2.11 mg/l to 53.2 (Ca) and 0.44 mg/l to 160 mg/l (Mg), respectively. Carbonate
(CO
3
) was not traced in all these samples.

4-36

The W2 sample had pH of 6.97 and DO of 3.89 mg/l. Both the pH and DO readings
were well within their respective Class III range limit. The pH reading also complied
with Class II but the DO concentration exceeded the Class II limit of 5.0 mg/l to 7.0
mg/l. Concentrations of BOD, TSS, ammoniacal nitrogen and counts of Total
Coliform recorded for this water samples were lower than their respective Class III
limits. BOD, TSS and total coliform were within their respective Class II limits. AN
however was 0.7 mg/l exceeding the Class II limit of 0.3 mg/l.

The COD concentration recorded was at 52 mg/l marginally higher than the Class III
limits of 50 mg/l, but much higher than the Class II limit of 25 mg/l.. Readings of
conductivity, TDS, Ca and Mg recorded at 8310 us/cm (conductivity), 4866 mg/l
(TDS), 34.9 mg/l (Ca) and 136mg/l (Mg). Carbonate (CO
3
) was well within the Class
III limit. The results obtained for the rest of the parameters tested were either not
detected or detected below their respective Class III limits

The two water samples (W3 and W4) collected from downstream of the first and
second drainage outlets had pH values of 6.87 (W3) and 6.45 (W4) which were well
within the Class III range limit of 5 to 9 and Class II limit of 6 to 9. DO was recorded
at of 3.57 mg/l (W3) which was also well within the Class III range limit of 3 mg/l to
5 mg/l, while DO reading in W4 which recorded 2.70 mg/l was lower than the said
limit. However, both W3 and W4 DO concentrations did not comply with the Class II
limit of 5.0 mg/l to 7.0 mg/l.

Concentrations of BOD, COD, TSS, and counts of Total Coliform recorded for these
two water samples were lower than their respective Class III limits for both the water
samples except for COD reading in sample W3 which recorded 65 mg/l being higher
than the COD Class III limit. BOD and TSS were also lower than their respective
Class II limits. COD at W3 of 65 mg/l exceeded the Class II limit of 25 mg/l while
W4 was just within the limit with 25 mg/l concentration. W3 had total coliform count
of 5,000 staying within the Class II limit of 5,000 mg/l, while W4 exceeded the limit
with 5,700 mg/l. Ammoniacal nitrogen readings were recorded at 1.4 mg/l (W3) and
14.9 mg/l (W4) respectively, which were higher than the Class III limit of 0.9 mg/l.
AN at both W3 and W4 exceeded Class II limit of 0.3 mg/l with 1.4 mg/l and 14.9
mg/l respectively.

Readings of conductivity, TDS, Ca and Mg for W3 and W4 were recorded at 1779
us/cm and 3230 us/cm (conductivity), 986 mg/l and 2039 mg/l (TDS), 8.46 mg/l and
16.0 (Ca), and 13.0 mg/l and 5.06 mg/l (Mg) respectively. Carbonate (CO
3
) was not
detected in both these two samples. Results for the rest of the parameters tested were
either not detected or detected below their respective Class III limits


4-37

The analytical results obtained for the samples collected at W1, W2, W3, W4, W5,
W6 and W7 during low tide are presented in Table 4.16 below while the laboratory
results are attached in Appendix 2.


4-38

Table 4.16: Water Quality Results (W1, W2, W3, W4, W5, W6 & W7) (Low Tide)

Results
Parameters Unit
W1 W2 W3 W4 W5 W6 W7
Class III Class II
pH value - 7.08 6.97 6.87 6.45 6.89 6.70 6.82 5 9 6 9
Biochemical Oxygen Demand mg/l <2 <2 <2 <2 <2 <2 <2 6 3
@ 5 days at 20 C
Chemical Oxygen Demand mg/l 54 52 65 25 55 55 48 50 25
Total Suspended Solids mg/l 12 9 14 <2 7 3 2 150 50
Mercury as Hg mg/l <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.004 0.001
Cadmium as Cd mg/l <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 0.001 0.01
6+
mg/l <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 1.4 0.01
Arsenic as As mg/l <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 0.40 0.05
Cyanide as CN mg/l <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 0.06 0.02
Lead as Pb mg/l
<0.01 <0.01 <0.01
<0.01 <0.01 <0.01 <0.01 0.02 0.05
3+
mg/l <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 2.50 -
Copper as Cu mg/l <0.005 <0.005 <0.005 0.015 0.014 0.005 <0.005 - 0.02
Manganese as Mn mg/l <0.01 <0.01 0.044 0.073 0.030 0.026 0.019 0.1 0.1
Nickel as Ni mg/l <0.05 <0.005 0.012 0.048 0.006 0.011 0.009
0.90 0.05
Tin as Sn mg/l <0.004 <0.004 <0.004 <0.004 <0.004 <0.004 <0.004
0.004 -

4-39
Results
Parameters Unit
W1 W2 W3 W4 W5 W6 W7
Class III Class II
Zinc as Zn mg/l <0.005 <0.005 0.032 0.054 0.032 0.018 <0.005 0.4 5
Free Chlorine as C1
2

mg/l <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
- N/A
Sulphide as S
2-
mg/l <0.05 0.20 0.40 0.40 0.40 0.30 0.20
- 0.05
Oil and Grease mg/l ND(<1)
ND(<1) ND(<1)
ND(<1) ND(<1) ND(<1) ND(<1)
Free from
visible layer,
discoloration,
deposits
Free from
visible layer,
discoloration,
deposits
Ammoniacal Nitrogen as N mg/l 0.7 0.7 1.4 14.9 0.6 0.6 0.5
0.9 0.3
Temperature C 29.8 30.2 30.1 31.0 29.6 29.7 29.2
Normal 2 Normal 2
Dissolved Oxygen mg/l 4.11 3.89 3.57 2.70 3.60 4.07 4.12 3 5 5 7
Conductivity us/cm 10450 8310 1779 3230 355 374 27
- 1000
Total Dissolved Solids mg/l 6182 4866 986 2039 239 222 36
- 1000
Total Coliform Count/100ml 1400 5000 5700 900 900 2400 600
50000 5000
Calcium as Ca mg/l 53.2 34.9 8.46 16.0 4.85 5.13 2.11
- -
Magnesium as Mg mg/l 160 136 13.0 5.06 4.56 5.03 0.44
- -
Silver as Ag mg/l <0.005 <0.005 <0.005 <0.005 0.094 <0.005 <0.005
0.0002 0.05
Barium as Ba mg/l <0.01 <0.01 0.01 0.03 0.03 0.02 0.05
- 1
Carbonate as CO
3
mg/l <1 <1 <1 <1 <1 <1 <1
-
1. Parameter limits of Class III under the DOE Proposed Interim National Water Quality Standards for Malaysia.
2. ND means not detected.

4-40

4.6.5 Alam Sekitar Malaysia (ASMA)
Secondary river water quality data for Sungai Balok and Sungai Tunggak from
published records for January and July 2007 were reviewed during the course of this
study. Data was obtained from Alam Sekitar Malaysia Sdn Bhd (ASMA), the
company that undertakes routine monitoring of river systems in Malaysia for the
Department of Environment (DOE). Table 4.17 lists the data for both rivers. The
location of the monitoring stations is indicated in Exhibit 4.16.


Upstream Sungai Balok, 4BL02

All parameters monitored at this location were within their respective Class III limits
for both monitoring dates. Iron however exceeded the limit of 1mg/l with 1.03mg/l in
July2007. Total coliform was 116,000 exceeded the Class III limit of 50,000.

Dissolved oxygen (DO), ammonical nitrogen (AN), conductivity, salinity and iron
exceeded their respective Class II limits during both monitoring times. Dissolved
solids, chlorine and total coliform only exceeded Class II limits for the July 2007
monitoring.

The water quality index (WQI) in July 2007 exceeded the Class II limit of 76.5 92.7
with 72, falling into a Class III category.

January 2007 monitoring has better water quality results probably due to the flushing
during the monsoon season.

Downstream Sungai Balok, 4BL01

Dissolved oxygen exceeded the Class III limit of 3-5 mg/l in January 2007 with 5.02
mg/l at the 4BL01 station at Sungai Balok indicating that the DO level is within the
higher Class II category. The BOD concentrations were observed to be low, falling
within the higher Class I category. Total coliform exceeded the limit of 50,000 during
both monitoring times with 52,000 and 101,000 for January and July 2007
respectively. All other parameters complied with the Class III limits at that location.

DO, chlorine and coliform exceeded the Class II limits of concentration during the
January and July 2007 monitoring. Arsenic exceeded the Class II limit of 0.05 mg/l
with 0.117 mg/l during the July 2007 monitoring.

The water quality index at this station was well within the Class II limit of 76.5 92.7
with 83 (January 2007) and 80 (July 2007).


4-41

Downstream Sungai Tunggak, 4T003

Dissolved oxygen at the Sungai Tunggak location of 4T003 exceeded the limit during
both monitoring in 2007 with 6.06 mg/l and 5.78 mg/l respectively in January and
July 2007. This indicates that the DO concentration is within the higher Class II
category. The BOD concentrations were observed to be low, falling within the higher
Class I category. Total coliform exceeded the Class III limit of 50,000 with 67,000 in
January 2007. Other than that, all other parameters complied with the Class III limits
at this location.

Dissolved solids, chlorine, arsenic and coliform exceeded their respective Class II
limits for both monitoring times (January and July 2007). TSS of 64 mg/l in July 2007
exceeded the Class II limit of 50 mg/l in July 2007.

The water quality index at this station was well within the Class II limit of 76.5 92.7
with 89 (January 2007) and 87 (July 2007).

Based on the monitoring data taken in January and July 2007 (representing the
monsoon and dry season respectively), both Sungai Balok and Sungai Tunggak
generally are seen to be of Class II river water quality standard.


4-42
Table 4.17: Secondary Water Quality Data from Sungai Balok & Sungai Tunggak

Results
4BL01 4BL02 4T003 Parameters Unit
24.01.2007 20.07.2007 24.01.2007 23.07.2007 24.01.2007 20.07.2007
Class III Class II
Dissolved Oxygen (saturated) - 70.8 73.3 67.3 51.58 82.3 88.9 N/A N/A
Dissolved Oxygen mg/l 5.02 5.00 4.97 3.94 6.06 5.78 3-5 5 7
Biochemical Oxygen Demand mg/l 1 1 1 2 1 1 6 3
@ 5 days at 20 C
Chemical Oxygen Demand mg/l 16 19 18
23
18
15
50 25
Total Suspended Solids mg/l 35 35 20 32 16 64 150 50
pH value - 7.62 7.42 7.79 6.20 7.89 7.21 5 9 6 9
NH
3
_N mg/l 0.26 1.00 0.48 0.84 0.11 0.15 0.9 0.3
NH
4
F mg/l N/A N/A 0.87 N/A N/A 0.20 N/A N/A
Cyanide as CN mg/l N/A N/A N/A N/A N/A N/A 0.06 0.02
Temperature C 29.97 29.09 29.90 28.60 29.86 28.61 Normal +2 Normal +2
Conductivity us/cm 18971 34643 5914 6173 21650 46662 - 1000
Salinity ppt 10.13 19.95 2.89 3.34 12.84 28.04 - 1
Turbidity NTU 17.8 13.5 31.3 22.7 30.2 8.3 - 50
Dissolved Solids, DS mg/l 2920 16100 29 3390 6460 20900 - 1000
Total Solids, TS mg/l 2955 16135 49 3422 6476 20964 N/A N/A
NO
3
mg/l 0.09 0.07 0.06 0.23 0.15 0.06 - 7
Chlorine, Cl mg/l 1500 8900 9 1810 3650 10400 - 200
PO
4
mg/l <0.01 0.02 0.01 0.02 <0.01 0.01 N/A N/A
Arsenic as As mg/l 0.009 0.117 <0.001 0.010 0.019 0.148 0.40 0.05

4-43
Results
4BL01 4BL02 4T003 Parameters Unit
24.01.2007 20.07.2007 24.01.2007 23.07.2007 24.01.2007 20.07.2007
Class III Class II
Mercury as Hg mg/l <0.0002 <0.0002 <0.0002 0.0002 <0.0002 <0.0002 0.004 0.001
Cadmium as Cd mg/l <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.01 0.01
Total Chromium

mg/l
<0.01 <0.01 <0.01 <0.01 <0.01 <0.01
N/A N/A
Lead as Pb mg/l <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.05
Zinc as Zn mg/l 0.09 0.02 0.13 0.03 0.04 0.02 0.4 5
Calcium, Ca mg/l 39.20 234.00 2.19 34.20 96.50 343.00 - -
Ferrum, Fe mg/l 0.86 0.04 0.88 1.03 0.41 0.02 1 0.3
Potassium, K mg/l 35.90 217.00 1.12 29.30 61.90 315.00 - -
Magnesium, Mg mg/l 110.00 790.00 2.13 99.30 267.00 1130.00 - -
Sodium, Na mg/l 912.0 5560.0 6.2 845.0 2170.0 5300.0 - -
Oil & Grease mg/l
<1 <1 <1 <1 <1 <1 Free from
visible layer,
discoloration
, deposits
Free from
visible layer,
discoloration
, deposits
MBAS mg/l <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 5,000 500
E.Coli - 1100 10000 16 12000 3900 5000 N/A N/A
Coliform - 52000 101000 1000 116000 67000 19000 50,000 5,000
WQ Index - 83 80 81 72 89 87 51.9 76.5 76.5 92.7
*Source: Alam Sekitar Malaysia Sdn Bhd (ASMA)

4-44

4.6.6 Riverbed Sediment Quality Monitoring

4.6.6.1 Riverbed Sediment Monitoring Locations

A total of four (4) riverbed sediment samples were collected from Sungai Balok using
the grab sampling technique. The details of these locations are presented in Table
4.18.

Table 4.18: Riverbed Sediment Monitoring Stations

Monitoring
Station
Description
Parameters
Monitored
S1 Sample collected 100 m downstream of the confluence of
Sungai Tunggak.
[N03 56.700 E103 22.331]

S2 Sample collected 100 m downstream of the second
drainage outlet (from the GIE).
[N03 57.872 E103 21.890]

S3 Sample collected 100 m downstream of the proposed
Lynas discharge outlet.
[N03 59.534 E103 21.472]

S4 Sample collected 100 m upstream of the road bridge
(across the Gebeng Bypass road).
[N04 00.381 E103 21.107]

Hg,
Cd,
As,
Pb,
Cu,
Mg,
Ni,
Sn,
Zn,
Ca,
Ag
TOC


4-45

4.6.6.2 Methodology

The riverbed sediment samples were collected by grab sampling technique, then were
preserved and sent back to the laboratory for chemical analysis. A summary of the
parameters analyzed and the analytical methods used for these riverbed sediment
samples is provided in Table 4.19.

Table 4.19: Method of Chemical Analysis

Parameters Methods
Mercury as Hg APHA 3120 B, 1995
Cadmium as Cd APHA 3120 B, 1995
Arsenic as As APHA 3120 B, 1995
Lead as Pb APHA 3120 B, 1995
Copper as Cu APHA 3120 B, 1995
Nickel as Ni APHA 3120 B, 1995
Zinc as Zn APHA 3120 B, 1995
Total Organic Carbon MS 679, Part III, 1980
Calcium as Ca APHA 3120 B, 1995
Magnesium as Mg APHA 3120 B, 1995
Silver as Ag APHA 3120 B, 1995
Tin as Sn APHA 3120 B, 1995


4-46


A summary of the chemical analysis for the riverbed sediment samples is provided in
Table 4.20 below.

All four riverbed samples had no presence of Hg, As, Sn and Ag when analysed for
heavy metals (Hg, Cd, As, Pb, Cu, Ni, Zn, Sn, and Ag). All other parameters were in
the range of 1-44 mg/kg, where zinc had the highest concentrations followed by lead.
Concentrations of alkaline metals analysed were for Ca and Mg which ranged from 89
mg/kg to 1038 mg/kg (Ca) and 208 mg/kg to 2085 mg/kg (Mg) respectively. The total
organic carbon (TOC) content of these sediment samples were found to be in the
range of 0.5 % w/w to 2.5 % w/w. It was observed that generally sample S1 had the
highest contents of heavy metals, alkaline metals and TOC, followed by sample S2,
S3 and the lowest being sample S4.

Table 4.20: Results of Chemical Analysis

Results
Parameters Unit
S1 S2 S3 S4
Mercury as Hg mg/kg <0.02 <0.02 <0.02 <0.02
Cadmium as Cd mg/kg 8.1 3.6 4.6 3.0
Arsenic as As mg/kg <0.1 <0.1 <0.1 <0.1
Lead as Pb mg/kg 18 13 2 1
Copper as Cu mg/kg 11 10 8 1
Nickel as Ni mg/kg 18 7 5 2
Tin as Sn mg/kg <0.4 <0.4 <0.4 <0.4
Zinc as Zn mg/kg 44 20 14 6
Calcium as Ca mg/kg 1038 381 147 89
Magnesium as Mg mg/kg 2085 747 208 445
Silver as Ag mg/kg <0.5 <0.5 <0.5 <0.5
Total Organic Carbon % w/w 2.5 1.9 0.7 0.5

4-47

4.6.7 Plankton

4.6.7.1 Monitoring Locations

A total of four (4) samples were collected to monitor plankton from Sungai Balok,
using the grab sampling technique. The details of these locations are presented in
Table 4.21.

Table 4.21: Plankton & Macrobenthos Monitoring Stations

Monitoring
Station
Description
Parameters
Monitored
P1/MB1 Sample collected 100 m downstream of the confluence of
Sungai Tunggak.
[N03 56.700 E103 22.331]

P2/MB2 Sample collected 100 m downstream of the second
drainage outlet (from the GIE).
[N03 57.872 E103 21.890]

P3/MB3 Sample collected downstream of the proposed Lynas
discharge outlet.
[N03 59.534 E103 21.472]

P4/MB4 Sample collected upstream of the road bridge (across the
Gebeng Bypass road).
[N04 00.381 E103 21.107]

Plankton and
Macrobenthos

4.6.7.2 Methodology

The plankton samples were sampled and analysed using the APHA 10200, 1995
methodology.

Sample Collection

Samples were collected as close to the water surface as possible. This is to ensure a
good representation of the composition of plankton at the various sites. The samples
were then preserved in formalin solution (40ml. buffered formalin to 1 litre of sample)
immediately upon collection. The sample bottles were stored in ice-cooled containers
for transportation to the laboratory where they were refrigerated before analysis was
carried out.

4-48

Concentration of Samples

The plankton (Phytoplankton and Zooplankton) collected in the water was
concentrated before analysis. The sedimentation technique was used for concentrating
the plankton (recommended by APHA). The method was preferred as it was non-
selective (unlike filtration) and non-destructive (unlike centrifugation). Qualitative
and quantitative analysis was carried out on the concentrated samples.

Sample Analysis

A standard compound microscope with 10x ocular and 10x, 20x, 40x, and 100x
objectives was used for the enumeration of plankton composition in the collected
samples. A stereomicroscope with zoom facility, 10x ocular and 1x to 8x objectives
was used for large plankters. The analysis of the density and diversity of the plankton
was carried out using the Lackey Drop Microtransect Counting method as
recommended by APHA.


A summary of plankton species recorded at the selected monitoring points are
tabulated as seen in Table 4.22 below.

Results of the analysis showed that plankton density and diversity was generally low
at all the monitoring locations. Plankton density varied from 5.72 x 10
3
plankton per
liter at P4, to 17.68 x 10
3
plankton per liter at P2. No one species of plankton was
observed to be the dominant plankton at any of the sampling sites. Mollusca larva
(zooplankton) was the most dominant plankton at P1, whereas Fragilaria (Freshwater
plankton) was observed to be dominant at P2 and P3, while Navicula (Freshwater
plankton) was the dominant plankton at P4. Mollusca larva was the dominant
plankton as correlated by the presence of a high density of Mollusca (5896 individuals
per m
2
) in the macrobenthos sample at site P1.

All the monitored locations showed a mixture of marine and freshwater plankton. A
total of only seventeen (17) species of plankton were recorded. The higher
distribution of marine plankton in the samples were Chaetoceros, Coscinodiscus,
Ditylum, Peridium, Pleurosigma, Rhizosolenia, Copepod, Mollusca larvae, and
Tintinnopsis, while Arcella, Fragilaria, Navicula, Nostoc, Spirogyra, Staurastrum,
Surirella and Tribonema were noted to be the higher distributed freshwater plankton
generally at all four locations. P1 sample was made up of 74% marine plankton and
26% freshwater plankton. Samples P2, P3 and P4 were made up of 84%, 78%, and
100% freshwater plankton respectively.

4-49

Diversity Index (H) at the monitoring locations showed values as low as 1.46 (sites P1
and P4) to a high of 1.74 (site P3).

The water samples collected from the various locations were found to have a high
content of suspended solids and was turbid (based on visual observation), except for
site P 1 where the sample was clear. The suspended solids were noted to be mainly of
decomposing vegetation. The high suspended solids and turbidity might have
contributed to a low plankton density and diversity.

The physical and chemical characteristics of the sampling sites affect the density,
diversity, distribution and stability of the plankton. Therefore the density and
distribution of plankton studied can be used as comparison in future monitoring
programme. The plankton monitoring report should be read in conjunction with the
monitoring report for the physio-chemical parameters, as changes in the physical
environment would eventually affect the ecology of the surrounding environment
including plankton.

Table 4.22: Results of Plankton Recorded at Monitoring Stations

Results
Plankton
P 1 P 2 P 3 P 4
Arcella * - 0.52 1.04 -
Chaetoceros - 0.26 - -
Coscinodiscus - 0.26 - -
Ditylum 0.26 - - -
Fragilaria * 2.08 6.50 4.16 0.26
Navicula * - 5.20 2.60 3.12
Nostoc * 0.52 1.56 1.04 -
Peridinium - - - 0.52
Pleurosigma 0.26 - - -
Rhizosolenia 0.78 - - -
Spirogyra * - 1.30 1.56 0.52
Staurastrum * - - - 0.26
Surirella * - 0.26 - -
Tribonema * - - - 0.26
Copepod 0.52 - 0.52 0.78
Mollusca Larvae 5.20 1.56 1.04 -
Tintinnopsis 0.26 0.26 - -
No. Per Litre ( X10
3
) 9.88 17.68 11.96 5.72
Shannon-Weiner Index (H) 1.46 1.70 1.74 1.46
Notes:
1. ND. Density less than 0.2 x 10
3
/litre.
2. * means freshwater Plankton.

4-50

4.6.8 Macrobenthos Monitoring

4.6.8.1 Macrobenthos Monitoring Locations

A total of four (4) samples were collected to monitor macrobenthos from Sungai
Balok using the grab sampling technique. These samples were taken from the same
locations as per the plankton monitoring. The details of these locations are presented
in Table 4.21 under the plankton monitoring section.

4.6.8.2 Methodology

The macrobenthos samples were sampled and analysed using the APHA 10500, 1995
methodology.

Sample Collection

An Ekman Grab sampler (0.15m x 0.15m) was used to sample the macrobenthos.
Samples were collected at the same locations where water samples were taken for
water quality and plankton analysis. The bottom grab samples collected were stored in
double layered plastic bags and kept in ice packed boxes before being transported to
the laboratory for analysis.

Sample Analysis

Analysis was carried out using the recommended method in the Standard Methods
for The Examination of Water and Wastewater published by the American Public
Health Association (APHA). Bottom grab samples were first diluted with water and
the slurry was then sieved through a series of sieves of mesh size 1.00mm aperture
(US standard No. 28 sieve) and mesh size 0.50mm aperture (US standard No. 35
sieve).

The screened material from the US Standard No.35 sieve was washed, collected in a
container and labelled. The content was then preserved in 70% alcohol. Using a
stereoscopic microscope, the samples were later identified and quantified. The
number of organisms observed was expressed as number of individuals per meter
square (individuals / m
2
).

4-51


A summary of Macrobenthos recorded at the selected monitoring points are tabulated
as seen in Table 4.23 below.

The analysis showed that the macrobenthos at locations MB1, MB2, MB3 and MB4
consisted of three (3) phyla of organisms. They were Annelida (Polychaeta),
Arthropoda (Crustacea) and Mollusca. A total of nine (9) species of organisms were
observed at the four locations. Three (3) species were recorded from Annelida; two
(2) species were recorded from Arthropoda (Crustacea), and four (4) species from the
Mollusca phyla. This indicated that there is a low diversity of macrobenthos at the
sampling locations.

The Mollusca was the dominant phylum with 95% of the total organisms in the
macrobenthic community. This was followed by Arthropoda (Crustacea) (3%) and
Annelida (2%).

There was a high content of decomposing vegetation observed in the samples
collected from all locations. Sediments collected from MB2 were found to be oily
(visual observation). It was also noted that all the samples emitted an odour of
Hydrogen Sulphide gas while the samples were being processed, an indication that the
monitoring locations could be polluted. Density of macrobenthos was low at all the
locations. The density of macrobenthos varied from sample to sample. The densest
sample was MB1 with 6116 individuals per m
2
. The least dense sample was MB2
with 44 individuals per m
2
. No macrobenthos was recorded at MB4 (ie: less than 44
individuals/m
2
).

Annelida was observed at MB1, MB2 and MB3 with densities between 44 and 88
individuals/m
2
. Arthropoda (Crustacea) was recorded at two (2) sites, namely MB1
and MB3. with densities of 176 individuals/m
2
(single species of Balanus
(Cirripedia), commonly known as barnacle) and 44 individuals/m
2
(single freshwater
species of Gammarus (Amphipoda)) respectively. Mollusca were also observed at
MB1 and MB3 with densities of 5896 individuals/m
2
(MB1) and 1144 individuals/m
2

(MB3).

Shannon-Wiener Diversity Index (H) is employed to measure the diversity of
macrobenthos at the monitoring sites. Diversity was low. Diversity Index (H) ranging
from 0 at locations MB 2 and MB 4, to 0.64 at location MB 3.

4-52

Physical and chemical factors such as sediment types, temperature, productivity,
salinity, oxygen and depth of the sampling sites are known to be among the various
factors that affect the density and composition of the macrobenthos. The density and
distribution of macrobenthos studied will provide useful data and information for
comparison in future monitoring programme. The macrobenthos monitoring report
should be read in conjunction with the monitoring report for the physio-chemical
parameters as well as the plankton data, as changes in the physical environment would
eventually affect the ecology of the surrounding environment.

Table 4.23: Results of Macrobenthos Recorded at Monitoring Stations

Results
Microbenthos
MB 1 MB 2 MB 3 MB 4
Annelida (Polychaeta)
- Lumbrineridea - - 88 -
- Nereidae - 44 - -
- Polychaete Tube 44 - - -
Total ( Annelida) 44 44 88 0

Arthropoda (Crustacea)
- Balanus (Cirripedia) 176 - - -
- Gammarus (Amphipoda) * - - 44 -
Total Arthropoda 176 0 44 0

Mollusca
- Cerithidea (Cerithiidae) 5676 - 88 -
- Donax (Donacidae) 88 - - -
- Littorina (Littorinidae) 132 - - -
- Turritella (Turritellidae) - - 1056 -
Total (Mollusca) 5896 0 1144 0

Total Density (Individuals/m
2
) 6116 44 1276 0
Sh- Weiner Index(H') 0.35 0.00 0.64 0.00
Notes:
1. 0 values mean Not Detected. Less than 44 Individuals/m2.
2. Above values are expressed as: Individuals/m2 except for SH-Weiner Index
3. * means Freshwater Macrobenthos.

4-53

4.6.9 Soil and Groundwater
A soil and groundwater investigation was performed at the proposed project site to
obtain baseline information regarding the environmental quality of the on-site soil and
groundwater. Soil and groundwater samples were collected at seven (7) locations
within the proposed project site boundary for chemical analyses (Exhibit 4.17). The
following sections describe the field activities and investigation methodology, and
results of the assessment.

4.6.9.1 Methodology
a. Drilling Protocol
Between 3 and 5 October 2007, seven (7) boreholes, designated MW1 through MW7,
were drilled at the proposed project site to a depth of 4 m below ground surface (bgs).
The boreholes were advanced using a cable tool percussion drill rig. No drilling fluids
were used. Soil samples were collected from the drill barrel and were visually logged
in accordance with the Unified Soil Classification System (USCS). Samples were also
checked for any unusual odour or staining. The soil boring logs are presented in
Exhibit 4.17.

b. Soil Sampling
A representative soil sample was selected at each borehole for chemical analysis,
biased toward any field evidence of contamination. The soil sample was screened for
total volatile organic vapour using the head space screening method using a photo-
ionizing detector (PID). In the absence of field evidence of contamination, a sample
above the water table was collected. Samples intended for chemical analyses were
placed in laboratory-supplied jars, properly labelled, and kept chilled until delivery to
the laboratory.

c. Installation of Groundwater Monitoring Wells
All boreholes were converted into 50 mm diameter permanent groundwater
monitoring wells. The well construction details at each borehole are presented in
Exhibit 4.17. Upon completion of installation, the monitoring wells were developed
to remove fine materials and establish hydraulic continuity between the target
groundwater zone and well intake area. Well development was performed using
dedicated bailers to minimize the potential of cross-contamination.

4-54

d. Well Elevation Survey and Static Water Level Measurement
All monitoring wells were surveyed for their top-of-casing levels. Stabilized standing
water level (SWL) measurements were obtained from each monitoring well on 6
October 2007. The SWL measurements and estimated groundwater elevations are
summarised in Table 4.24.

On the basis of the measured static water levels in the wells, groundwater was
generally encountered at shallow depths of between 0.97 and 2.17 m bgs. Based on
the derived groundwater reduced levels, the groundwater beneath the subject site is
inferred to flow towards the south. The inferred groundwater flow direction is shown
in Exhibit 4.17. The groundwater gradient at the site is calculated to be
approximately 0.001.

Table 4.24: Groundwater Elevation Data
Top-of-Well Casing
Elevation
Depth to
Groundwater
Groundwater
Elevation
Depth to
Groundwater Monitoring Well
Number
(m RL) (m below TOC)
[1]
(m RL) (m BGS)
MW1 7.97 1.39 6.58 0.97
MW2 7.99 1.60 6.39 1.13
MW3 8.35 2.60 5.75 2.17
MW4 8.41 1.74 6.67 1.26
MW5 8.19 1.86 6.33 1.43
MW6 8.47 1.88 6.59 1.48
MW7 8.32 1.43 6.89 1.04
Notes:
m below TOC - metre below top of well casing; m RL - metre reduced level;
[1]
Measurements taken on
6 October 2007.

e. Groundwater Sampling

The groundwater monitoring wells were sampled on 6 October 2007. Sampling was
performed using dedicated bailers. A minimum of three well volumes of standing
groundwater in each well was purged prior to obtaining a sample. Groundwater
recovery rates during purging were observed to be low to moderate. Samples were
placed in laboratory-supplied containers, properly labelled and kept chilled until
delivery to the laboratory.

4-55

4.6.9.2 Laboratory Analyses

A total of eight (8) soil and eight (8) groundwater samples, including 1 soil and 1
groundwater duplicates were submitted to the laboratory for chemical analysis. ALS
Technichem (M) Sdn. Bhd. was engaged to perform chemical analyses of the soil and
groundwater samples. The samples were analysed for:

Total Petroleum Hydrocarbons (TPH);

Volatile Organic Compounds (VOC) comprising 63 individual compounds of
monocyclic aromatics, fumigants, halogenated aliphatics, halogenated
aromatics, trihalomethanes and oxygenated compounds;

Semi-Volatile Organic Compounds (SVOC) comprising 87 individual
compounds of polycyclic aromatic hydrocarbons (PAHs), phenols, phthalate
esters, nitrosamines, nitroaromatics, ketones, haloethers, chlorinated
hydrocarbons, anilines and benzidines;

Pesticides comprising 17 individual organochlorine and 14 organiphosphorus
pesticide compounds;

Polychlorinated biphenyls (PCB);

Metals comprising arsenic, barium, cadmium, chromium, cobalt, copper,
mercury, lead, molybdenum, nickel, zinc and antimony;

Cyanide;

Anions (chloride, sulphate and phosphate) in groundwater; and

Cations (sodium, potassium, calcium and magnesium) in groundwater.

4.6.9.3 Results and Discussion

As there are currently no compound-specific reference standards for assessing the
presence of soil and groundwater impact in Malaysia, the baseline analytical results
were compared with the Dutch Ministry of Housing, Spatial Planning and the
Environment (MVROM)Soil and Groundwater Standards to assess soil and
groundwater quality. Though not enforceable in Malaysia, these standards are widely
used in the evaluation of soil and groundwater quality in Malaysia and other countries
outside of the Netherlands. The MVROM standards can be used as a guideline
reference /investigation/screening criteria for this site.

4-56

The MVROM standards are subdivided into two general categories:

Target values are characteristic of clean, uncontaminated soil and
groundwater, representative of background values in the Netherlands; and

Intervention values indicate the presence of constituents or compounds at
levels above which there is a serious case of soil and groundwater
contamination.

Given the proposed industrial use of the site and its surroundings, the above generic
screening criteria are likely to be over-protective, particularly the target values
(DTV). The Dutch Intervention Values (DIV) has been selected as the appropriate
baseline screening criteria for this site.

a. Soil Sampling Observations and Analytical Results

Soils encountered during soil boring and sampling activities throughout the field
survey did not exhibit any apparent evidence of contamination, i.e. on the basis of the
soil headspace screening and visual and olfactory inspection. Measured soil total
organic vapour values indicated negligible concentrations of ionizable VOCs.

Table 4.25 summarises the laboratory analytical results for soil samples while the
complete laboratory results are attached in Appendix 2. The results indicate that all
organic parameters (TPH, VOC, SVOCs, pesticides and PCBs) and cyanide were
below their respective laboratory level of reporting (LOR) in all soil samples
analyzed. A few metals were detected above their respective LOR, however, the
detected levels were below the respective DTVs and DIVs.

b. Groundwater Sampling Results

During the gauging and sampling episodes, no oily sheen or hydrocarbon odour was
observed in any groundwater samples. Field water quality parameters measured
indicated the following:

Groundwater pH ranged between 3.6 and 4.0 indicating acidic conditions,
generally associated with peaty swampy conditions;

Electrical conductivity ranged between 1 S/cm and 82 S/cm, indicative of
very low total dissolved solids content (ie. freshwater conditions);

Dissolved oxygen ranged between 2.6 and 4.4 mg/l, indicative of low to
moderate dissolved oxygen content; and

4-57

Oxidation and reduction potential (ORP) ranged between 154 and 275 mV,
indicative of slightly oxidizing conditions.

The groundwater analytical results are summarised in Table 4.26. The full laboratory
results are presented in Appendix 2. The results indicate that:

Selected metals were detected at or above their respective LORs in a few of
the groundwater samples. However, the detected levels were below the
respective DTVs and DIVs, with the exception of barium in MW4 detected at
a concentration of 57 g/l which slightly exceeded the DTV of 50 g/l. The
DIV for barium is 625 g/l. The concentrations of all other metals analyzed
were below the respective LORs and DIVs; and

All organic parameters (TPH, VOC, SVOCs, pesticides and PCBs) and
cyanide were below their respective laboratory level of reporting (LOR) in all
groundwater samples analyzed.

Concentrations of chloride, sulphate and phosphate ranged from 7.510.5
mg/l, 1.428 mg/l, and 0.10.82 mg/l respectively. Calcium, magnesium,
sodium and potassium were detected at concentrations of 0.43.3 mg/l, 0.1
0.6 mg/l, 2.323.4 mg/l, and 0.31.7 mg/l respectively. Guideline values have
not been set by MVROM for these anions and cations. The concentrations
were considered low and indicative of natural background levels.

b. QA/QC Results
One duplicate soil sample (labelled as MW8(1.0m)) of MW2(1.0m) and one duplicate
groundwater sample (labelled as MW8) of MW6 were collected. Relative percentage
difference (%RPD) for all analytes were within the acceptable RPD criteria except for
phosphate and sodium in groundwater. These variances are noted to not have any
material implications in the overall conclusions of the baseline soil and groundwater
assessment.

4-58

PID Dutch List - Organic Analytes
Other Organic Analytes
(3)
Aromatic
Compounds
Polycyclic
Aromatic
Hydrocarbons
Chlorinated
Hydrocarbons Pesticides
Volatile
Organic
Compounds
Semivolatile
Organic
Compounds
Organochlorine &
Organophosphorus
Pesticides
Polychorinated
Biphenyls
M
a
x
i
m
u
m

R
e
a
d
i
n
g
1
0

C
o
u
m
p
o
u
n
d
s
1
0

C
o
m
p
o
u
n
d
s
2
9

C
o
m
p
o
u
n
d
s
1
7

C
o
m
p
o
u
n
d
s
6

c
o
m
p
o
u
n
d
s
M
i
n
e
r
a
l

O
i
l
C
6
-
C
9
C
1
0
-
C
1
4
C
1
5
-
C
2
8
C
2
9
-
C
3
6
6
3

C
o
m
p
o
u
n
d
s
8
7

C
o
m
p
o
u
n
d
s
3
1

C
o
m
p
o
u
n
d
s
1
0

C
o
m
p
o
u
n
d
s
ppm mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg
Limit of Reporting (LOR) Various Various Various Various Various 5 5 50 100 100 Various Various Various Various
Screening Criteria
Dutch Target Values
(1)
Various Various Various Various Various 50 NS NS NS NS Various
(2)
Various
(2)
Various
(2)
NS
Dutch Intervention Values
(1)
(2)
Various
(2)
Various
(2)
NS
Sample ID
MW1 (1.0m) 0 ND ND ND ND ND ND ND ND ND ND ND ND ND ND
QA/QC Sample - Duplicate of MW2
RPD (%) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Notes:
mg/kg - milligrams per kilogram indicates value exceeding the Dutch Intervention Value (DIV)
NS - DIV or DTV not specified indicates exceedance of the acceptable QA/QC criteria (RPD of less than -30% or exceeding 30%)
ND - not detected above the Limit of Reporting (LOR) Where both analytical values of the primary and duplicate samples are below 10 times the LOR, RPDs of 50% are considered acceptable.
(1)
Dutch Ministry of Housing, Spatial Planning and Environment (MVROM). Circular on Target and Intervention Values for Soil Remediation. February 2000.
(2)
Values are available for selected compounds only. Refer to the relevant documents for further information.
(3)
Some compounds are the same as the Dutch List compounds.
Other Pollutants
Total
Petroleum
Hydrocarbons
TABLE 4.25: Summary of Detected Constituents in Soil

4-59

Cyanide Metals
T
o
t
a
l

C
y
a
n
i
d
e
A
r
s
e
n
i
c
B
a
r
i
u
m
C
a
d
m
i
u
m
C
h
r
o
m
i
u
m
C
o
b
a
l
t
C
o
p
p
e
r
M
e
r
c
u
r
y
L
e
a
d
M
o
l
y
b
d
e
n
u
m
N
i
c
k
e
l
Z
i
n
c
A
n
t
i
m
o
n
y
mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg
Limit of Reporting (LOR) 0.5 1 5 0.05 0.05 0.5 0.5 0.05 1 0.5 0.5 0.5 5
Screening Criteria
Dutch Target Values
(1)
NS 29 160 0.8 100 9 36 0.3 85 3 35 140 3
(1)
NS 55 625 12 380 240 190 10 530 200 210 720 15
Sample ID
MW1 (1.0m) ND ND ND ND 65 1 4 0.1 4 ND 1 7 ND
MW2 (1.0m) ND ND ND ND 1 ND 2 0.1 1 ND ND ND ND
MW3 (1.0m) ND ND ND ND 2 ND 2 0.1 ND ND ND 1 ND
MW4 (1.0m) ND ND 7 0.1 75 6 7 0.1 4 ND 2 6 ND
MW5 (1.0m) ND ND ND 0.1 79 1 6 0.1 2 ND 1 6 ND
MW8 (1.0m) ND ND ND ND 1 ND 2 0.1 1 ND ND 1 ND
RPD (%) 0 0 0 0 0 0 0 0 0 0 0 18 0
Notes:
mg/kg - milligrams per kilogram indicates value exceeding the Dutch Intervention Value (DIV)
ND - not detected above the LOR Where both analytical values of the primary and duplicate samples are below 10 times the LOR, RPDs of 50% are considered acceptable.
(1)
Inorganic Analytes
Table 4.25 (Con't): Summary of Detected Constituents in Soil

4-60
Dutch List - Organic Analytes
Other Organic Analytes
(3)
Aromatic
Compounds
Polycyclic
Aromatic
Hydrocarbons
Chlorinated
Hydrocarbons Pesticides
Volatile
Organic
Compounds
Semivolatile
Organic
Compounds
Organochlorine &
Organophosphorus
Pesticides
Polychorinated
Biphenyls
1
0

C
o
u
m
p
o
u
n
d
s
1
0

C
o
m
p
o
u
n
d
s
2
9

C
o
m
p
o
u
n
d
s
1
7

C
o
m
p
o
u
n
d
s
6

c
o
m
p
o
u
n
d
s
M
i
n
e
r
a
l

O
i
l
C
6
-
C
9
C
1
0
-
C
1
4
C
1
5
-
C
2
8
C
2
9
-
C
3
6
6
3

C
o
m
p
o
u
n
d
s
8
7

C
o
m
p
o
u
n
d
s
3
1

C
o
m
p
o
u
n
d
s
1
0

C
o
m
p
o
u
n
d
s
g/l g/l g/l g/l g/l g/l g/l g/l g/l g/l g/l g/l g/l g/l
Limit of Reporting (LOR) Various Various Various Various Various 5 5 50 100 100 Various Various Various Various
Screening Criteria
Dutch Target Values
(1)
(2)
Various
(2)
Various
(2)
NS
(1)
(2)
Various
(2)
Various
(2)
NS
Sample ID
MW1 ND ND ND ND ND ND ND ND ND ND ND ND ND ND
RPD (%) 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Trip Blank - - - - - - - - - - ND - - -
Notes:
g/l - micrograms per litre indicates exceedance of DIV
ND - not detected / below LOR Where both analytical values of the primary and duplicate samples are below 10 times the LOR, RPDs of 50% are considered acceptable.
(1)
(2)
Values are available for selected compounds only. Refer to the relevant documents for further information.
(3)
Some compounds are the same as the Dutch List compounds.
Other Pollutants
Total
Petroleum
Hydrocarbons
Table 4.26: Summary of Detected Constituents in Ground Water

4-61
Cyanide Trace Metals
T
o
t
a
l

C
y
a
n
i
d
e
C
h
l
o
r
i
d
e
S
u
l
p
h
a
t
e
P
h
o
s
p
h
a
t
e
A
l
k
a
l
i
n
i
t
y
C
a
l
c
i
u
m
M
a
g
n
e
s
i
u
m
S
o
d
i
u
m
P
o
t
a
s
s
i
u
m
A
r
s
e
n
i
c
B
a
r
i
u
m
C
a
d
m
i
u
m
C
h
r
o
m
i
u
m
C
o
b
a
l
t
C
o
p
p
e
r
M
e
r
c
u
r
y
L
e
a
d
M
o
l
y
b
d
e
n
u
m
N
i
c
k
e
l
Z
i
n
c
A
n
t
i
m
o
n
y
mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l g/l g/l g/l g/l g/l g/l g/l g/l g/l g/l g/l g/l
Limit of Reporting (LOR) 0.05 0.1 0.1 0.01 1 0.1 0.1 0.1 0.1 1 5 1 1 1 1 0.3 1 1 1 5 1
Screening Criteria
Dutch Target Values
(1)
NS NS NS NS NS NS NS NS NS 10 50 0.4 1 20 15 0.05 15 5 15 65 -
(1)
NS NS NS NS NS NS NS NS NS 60 625 6 30 100 75 0.3 75 300 75 800 20
Sample ID
MW1 ND 10.5 27.8 0.76 21 0.4 ND 23.4 0.6 ND 4 ND 1 ND ND ND ND ND ND 6 ND
MW2 ND 7.7 2.4 0.82 2 1.1 0.5 5.3 0.9 ND 12 ND ND ND ND ND ND ND 2 11 ND
MW3 ND 10.0 1.4 ND ND 1.0 0.4 3.2 0.7 ND 8 ND ND 1 ND ND ND ND 2 13 ND
MW4 ND 11.4 11.2 ND ND 3.1 0.6 4.4 1.7 ND 57 ND ND 1 ND ND 14 ND 2 14 ND
MW5 ND 9.0 4.9 ND ND 1.3 0.3 3.0 0.3 ND 16 ND ND 2 ND ND ND ND 1 14 ND
MW6 ND 8.2 8.7 ND ND 1.9 0.4 2.3 0.5 2 19 ND ND 8 ND ND 2 ND 7 22 ND
MW7 ND 7.5 3.9 0.03 1 3.3 0.3 2.5 0.5 2 18 ND ND ND ND ND 7 ND 1 21 ND
MW8 ND 8.2 8.5 0.09 ND 1.8 0.4 4.6 0.6 2 17 ND ND 7 ND ND 2 ND 5 20 ND
RPD (%) 0 0 -2 160 0 -5 0 67 18 0 -11 0 0 -13 0 0 0 0 -33 -10 0
Trip Blank - - - - - - - - - - - - - - - - - - - -
Notes:
g/l - micrograms per litre indicates exceedance of DIV
ND - not detected / below LOR Where both analytical values of the primary and duplicate samples are below 10 times the LOR, RPDs of 50% are considered acceptable.
[1]
Inorganic Analytes
Table 4.26 (Con't): Summary of Detected Constituents in Ground Water
Common Metals Anions
Preliminary Environmental Impact Assessmentand

4-62

4.7 ECOLOGY

The proposed plant site has been largely cleared and filled to the existing platform
level. Secondary vegetation were found sparsely distributed within the site. The
vegetation type is typical of a disturbed area, and all species observed are very
common pioneer and invasive species, typical of an open and disturbed vegetation
type. No vegetation of ecological significance was observed at the site.


4-63

4.8 SOCIO-ECONOMIC ENVIRONMENT

Kuantan with an area of 2,960 km
2
, is divided into seven districts comprising a total
population of 394,500 (Statistics Department Malaysia 2004).

Based on the Population and Housing Census of Malaysia (2000), the Kuantan
township has a total population of 344,319. The mukim (sub-district) where the site is
located, Sungai Karang, has a population of 31,625. Based on the population records,
the population distribution in Kuantan is not uniform. The population of the mukims
closest to the site in Sungai Karang, i.e. Beserah in the south is 11,744, and Kuala
Kuantan (south of Beserah) is 269,721 estimated people. Sungai Karang is the second
most populous sub-district in Kuatan with 31,625 people accounting for
approximately 9.2% of the Kuantan District population.

These three sub-districts are highly populated with respect to the other sub-districts in
Kuantan. Kuala Kuantan is the most populous as it the capital city of the state of
Pahang with all state administrative offices located there. Sungai Karang and Beserah
are the next two most populous sub-districts and this is attributed primarily to the
development of the GIE and the Kuantan Port, generating significant employment
opportunities. Of the total population in these 3 mukims, Malaysian citizens
comprised 97.7 % whilst the remaining was made up of non-citizens (2.3%).

Based on the Structure Plan of Kuantan (2015), the Kuantan district population is
projected to increase to more than 590,000 people in 2015, whilst the population of
Sungai Karang and Beserah combined is expected to reach almost 88,417 persons
compared to 43,369 current population. The average population growth is forecasted
to be 4.2% a year for the period 20052015.

The main labour workforce within the age bracket of 2064 years comprises 51.6% of
the total population of the Kuantan district. The structure plan also notes that in 2000,
the majority (26.5%) of the existing work force in the district was employed in
community service, social service and self-employment. About 24.53% of the
workforce was employed in the manufacturing and construction sectors. By year
2015, this industrial sector workforce is forecasted to almost triple the number.

The Lynas project site will be discharging its effluent into a drain that leads into
Sungai Balok. According to the Department of Fisheries (Kuantan branch), there are
fishing villagers at Sungai Balok, particularly at the river mouth leading into the
South China Sea. Apparently, these fishermen are 100% dependent on the sea, and not
dependent on Sungai Balok. Sungai Balok in itself is occasionally used by anglers
who fish during their pass time or as a hobby.

4-64

4.9 PORT OF KUANTAN
Kuantan Port is an all weather deep sea port situated strategically at Tanjung Gelang
(Latitude 358'N, Longitude 103 26'E) some 25 kilometres North of the fast growing
municipality of Kuantan in the State of Pahang at the crossroad of international
shipping lanes of the South China Sea. The port is the gateway for trading between
Malaysia and the Far East and linking the East Coast State of Peninsular Malaysia to
the rest of the world. Kuantan Port is an ISPS-compliant, multipurpose all-weather
port with road and rail networks that make it the leading maritime trade and logistics
centre in the East Coast Region of Peninsular Malaysia.
Kuantan Port handles various type of cargoes including containerized cargo, bulk
cargo (dry & liquid) and break bulk. It has been privatised since 1998 and is currently
managed and operated by Kuantan Port Consortium Sdn Bhd. In year 2006, it handled
more than 10,650,000 tonnes of cargo.
Kuantan Port Authority is a Federal Statutory Body established on 1st September
1974 under the Port Authorities Act 1963 and placed under the purview of Ministry of
Transport.
Kuantan Port is also well-connected by road and rail to other parts of Peninsular
Malaysia and by air to major world destinations via Kuala Lumpur. Located
approximately 220 kilometres away from Kuala Lumpur, Kuantan Port is about 3
hours by road or 40 minutes by air from Kuala Lumpur. Kuantan Airport is 12
kilometres to Kuantan town and approximately 38 kilometres to the Port.
The port also has warehousing facilities. The existing warehouse at the port can be
used if required for the transit storage of the Lanthanide concentrate.

The layout of the port is presented in Exhibit 4.18. The Kuantan Port Industrial Area
is made up of mainly tankage storage areas and chemical plants such as Kaneka,
Petronas, BASF, Mobil and Shell. There also is some area set aside as warehouse
facilities. These include facilities like Felda and Kuantan Oleo Chemical.

For the export of the finished products, Lynas is will truck the containers to the
Kuantan Port for shipment overseas. The Kuantan Port is located about 5km south-
east of the GIE.

4-65

4.10 ROAD NETWORK

The Gebeng Industrial Estate (GIE) is linked to the major town of Kuantan and
regional port and airport by the main coastal trunk road, Jalan Kuantan-Kemaman
(Federal Route 3) and the East Coast Highway. These links also provide access to the
southern tip of Johor Bahru whilst the East-West Highway to the north of the
industrial area (North of Terengganu) provides direct access to Penang, Ipoh and
other major towns in the North-West. The existing road network is presented in
Exhibit 4.19.

Jalan Kuantan-Kemaman which is part of Federal Route 3 is a single lane dual
carriageway road. At present, there are three roads that connect the Gebeng Industrial
Area to the Jalan Kuantan-Kemaman.

Gebeng Bypass bypasses the area of Kuantan Port and is a 2-lane dual carriageway.
Currently, there is only one road that connects the Gebeng Bypass to the GIE.

The proposed plant site is connected to the Kuantan Port through Jalan Kuantan-
Kemaman and Jalan Gebeng Bypass. Jalan Kuantan-Kemaman is located at the south
of the development site, whilst Jalan Gebeng Bypass is located at the north of the
plant site. The plant site is connected to Jalan Kuantan Kemaman through three
roads i.e. Jalan Gebeng 1/1, Jalan Gebeng 1/11 and Jalan Gebeng 2/5, whilst the plant
site is connected to the Gebeng Bypass through an existing road located at the west of
the plant site.

The roads within the Gebeng Industrial Estate including the road in front of the
proposed plant site are mainly 2-lane roads with varying carriageway widths.


5-1

CHAPTER FIVE
5.0 POTENTIAL ENVIRONMENTAL IMPACTS AND RECOMMENDED
MITIGATION MEASURES

5.1 INTRODUCTION

This chapter of the study assesses the potential environmental impacts arising from the
construction and operation of the proposed Advanced Materials Plant within the Gebeng
Industrial Estate in Kuantan, Pahang and recommends suitable mitigation measures to
minimise these impacts to a sustainable level, ensuring compliance to governing
legislation on environmental protection.

The assessment is presented under the following sub-headings:

Surface Water
Soil and Groundwater
Ambient Noise
Solid Waste
Ambient Air
Socio-Economic Issues
Biological Resources
Traffic and Transportation

The relevant legislation and standards governing these issues which are applicable to the
project are also discussed under each of the above sub-headings. The potential
adverse/beneficial impacts and the recommended mitigation measures are discussed
under two sections; each section representing a stage in the life-cycle of the project, i.e.
construction and operational phases. As the proposed plant will be constructed on an
industrial plot already cleared and filled, the activities carried out for the pre-operational
phase such as the geotechnical investigation, topographical surveys, and baseline
environmental sampling will not impact the environment at the site. Therefore, these
impacts will not be assessed further in this chapter.

In the assessment process, the impacts are categorized based on their duration of
occurrence:

Short-term impacts: Impacts which are temporary or transient in nature and will
occur during the construction phase of the project. This category of impact will
diminish/become non-existent as soon as the construction phase of the project is
completed.

Long-term impacts: Impacts which are chronic in nature and may prevail throughout
the operational lifetime of the Advanced Materials Plant.

5-2

Permanent impacts: Impacts which result in a permanent/irreversible change to
existing environmental resources in the vicinity of the project.

It is noteworthy to state that the potential impacts cannot be predicted with absolute
certainty. Predictions are limited by the quality and certainty of information provided or
available and the accuracy of predictive techniques employed is a function of the level of
scientific knowledge or understanding. Therefore the predictions and assessment
presented in this chapter should be viewed as general indications of the likely magnitude
and significant of possible impacts. Where information is unavailable or uncertain, or
where extrapolations have been made, these have been made explicit in each case.

5.2 SURFACE WATER

5.2.1 Regulatory Requirements

The proposed Advanced Materials Plant site is located within the catchment of Sungai
Balok. As there are no potable water abstraction stations located within this catchment,
all sewage and industrial wastewaters generated from the operation of the plant shall
comply with the less stringent Standard B discharge limits stipulated in the
Environmental Quality (Sewage and Industrial) Effluent Regulations, 1978. These limits
are presented in Table 5.2.1.

Discharges from sediment retention structures including silt traps constructed during the
construction phase of developmental projects are regulated by the concentration of Total
Suspended Solids (TSP) and Oil and Grease (O&G). Typically, for construction projects,
the Department of Environment (DOE) will impose a control limit of 50 mg/l or 100
mg/l for TSS (depending on the sensitivity of the receiving water course) and the
absence of any O&G traces in the overflow from these structures. The limit will be
specified by DOE in the EIA approval conditions.

Inland waters including river systems are classified into five classes based on the
National Interim Water Quality Standards for Malaysia (NIWQSM). The classes of the
NIWQSM are as follows:

Class I : Conservation of natural water supply- practically no treatment necessary
Class IIA: Conventional treatment required
Class IIB: Recreational use with body contact.
Class III: Extensive treatment required
Class IV: Irrigation
Class V: None of the above

The NWQSM criteria limits for all five classes are presented in Table 5.2.2.

5-3

Table 5.2.1: Standard A and B Effluent Discharge Limits
2

Parameter Unit Standard
A B
Temperature o
C
40 40
pH Value 6.0-9.0 5.5-9.0
BOD
5
at 20
o
C
mg/l 20 50
COD mg/l 50 100
Suspended Solids mg/l 50 100
Mercury mg/l 0.005 0.05
Cadmium mg/l 0.01 0.02
Chromium,VI mg/l 0.05 0.05
Arsenic mg/l 0.05 0.10
Cyanide mg/l 0.05 0.10
Lead mg/l 0.10 0.5
Chromium III mg/l 0.20 1.0
Copper mg/l 0.20 1.0
Manganese mg/l 0.20 1.0
Nickel mg/l 0.20 1.0
Tin mg/l 0.20 1.0
Zinc mg/l 1.0 1.0
Boron mg/l 1.0 4.0
Iron mg/l 1.0 5.0
Phenol mg/l 0.0001 1.0
Free Chlorine mg/l 1.0 2.0
Sulphide mg/l 0.50 0.50
Oil and Grease mg/l ND 10.0
ND: Not Detected
Standard A: Applicable to discharges arising within water supply catchment areas
Standard B: Applicable to other inland waters (outside catchment areas) or any part of the sea abutting the
foreshoe and other body of natural or artificial surface or subsurface water.

2
Schedule III, Environmental Quality (Sewage and Industrial Effluent) Regulations, 1979

5-4

Table 5.2.2: National Interim Water Quality Standards for Inland Waters

Classes
Parameters

(Units) I IIA IIB III IV V
Ammoniacal
Nitrogen
mg/l 0.1 0.3 0.3 0.9 2.7 >2.7
BOD mg/l 1 3 3 6 12 >12
COD mg/l 10 25 25 50 100 >100
DO mg/l 7 5-7 5-7 3-5 <3 <1
pH 6.5-8.5 6-9 6-9 5-9 5-9 -
Colour TCU 15 150 150 - - -
Elect. Cond.* mhos/c
m
1000 1000 - - 6000 -
Floatables N N N - - -
Odour N N N - - -
Salinity* /
00
0.5 1 - - 2 -
Taste N N N - - -
Total Diss. Solid* mg/l 500 1000 - - 4000 -
Total Susp. Solids mg/l 25 50 50 150 300 >300
Temperature C - Normal
2
- Normal
2
- -
Turbidity NTU 5 50 50 - - -
Feacal coliform.** Counts/
100ml
10 100 400 5000
(20000)

5000
(20000)

Total Coliform. Counts/
100ml
100 5000 5000 50000 50000 >50000
AI mg/I - - (0.06) 0.5
As mg/I | 0.05 0.4 (0.05) 0.1 |
Ba mg/I | 1 - - |
Cd mg/I | 0.01 0.01* (0.001) 0.01 |
Cr (VI) mg/I | 0.05 1.4 (0.05) 0.1 |
Cr (III) mg/I | - 2.5 - |
Cu mg/I | 1 - 0.2 |
Hardness mg/I | 250 - - |
Ca mg/I | - - - |
Mg mg/I | - - - |
Na mg/I | - - 3 SAR |
K mg/I | - - - |
Fe mg/I | 0.3 1 1 (leaf) |
N 5 L
Pb mg/I A 0.05 0.02* (0.01) 5 E
Mn mg/I T 0.1 0.1 0.2 V
Hg mg/I U 0.001 0.004 (0.0001) 0.002 E
Ni mg/I R 0.05 0.9* 0.2 L
Se mg/I A 0.01 0.25 (0.04) 0.02 S
Ag mg/I L 0.05 0.0002 -
Sn mg/I - 0.004 - A
U mg/I L - - - B
Zn mg/I E 5 0.4* 2


5-5

Table 5.2.2: National Interim Water Quality Standards for Inland Waters (contd)

V V
B mg/I E 1 - (3.4) 0.8 E
CI mg/I L 200 - 80
CI
2
mg/I | - - (0.02) - IV
CN mg/I | 0.02 0.06 (0.02) - |
F mg/I | 1.5 10 1 |
NO
2
mg/I | 0.4 0.4 (0.03) - |
NO
3
mg/I | 7 - 5 |
P mg/I | 0.2 0.1 - |
Si mg/I | -50 - - |
SO
4
mg/I | 250 - - |
S mg/I | 0.05 - (0.001) - |
CO
2
mg/I | - - - |
Gross - Be/I | 0.1 - - |
Gross - Be/I | 1 - - |
Ra 226 Bq/I | <0.1 - - |
Sr - 90 Bq/I <1 - -
*: At hardness 50 mg/I CaCO
3.
@: Maximum (outside parentheses) and 24 hr average (inside
parentheses) concentrations
N: No visible floatable material/ debris, no objectionable odour, no objectionable taste.
*: Related parameters, only one recommended for use
**: Geometric mean
: Maximum not to be exceeded


5-6

Table 5.2.2: National Interim Water Quality Standards (INWQS) (contd)

Classes Parameters (Units)
I IIA/IIB III@ III IV V
CCE g/I 500 - - -
MBAS/BAS g/I N 500 5000 (200) - -
O & G (mineral) g/I A 40;N N - -
O & G (emulsified
edible)
g/I T 7000;N N - -
PCB g/I L 0.1 6 (0.05) - -
Phenol g/I E 10 - - -
V
Aldrin / g/I E 0.02 0.2 (0.01) - -
Dieldrin L
BHC g/I S 2 9 (0.1) - -
Chlordane g/I 0.08 2 (0.02) - -
t-DDT g/I O 0.1 1 (0.01) - -
Endosulfan g/I R 10 - - -
Heptachlor / g/I 0.05 0.9 (0.06) - -
Epoxide A
Lindane g/I B 2 3 (0.4) - -
S
2, 4-D g/I E 70 450 - -
2, 4, 5 - T g/I N 10 160 - -
2, 4, 5 TP g/I T 4 850 - -
Paraquat g/I 10 1800 - -
N: Free from visible film, sheen, discoloration and deposits
@: Maximum (outside parentheses)) and 24 hr average (inside parentheses) concentration

5-7

5.2.2 Construction Phase

The total area of the proposed plant site is 100 ha. The site was developed in the mid
90s as part of the Phase III expansion of the Gebeng Industrial Estate (GIE) and thus
has been cleared and filled to the existing platform level. However, sparse pockets of
secondary vegetation and shrubs can be found within the site.

5.2.2.1 Potential Sources of Impacts

Sources of water quality impacts predicted during the construction phase include:

Site preparation works;
Construction runoff and drainage; and
Sewage from on-site worker camps (if the construction labour force is housed on-
site).

a. Site Preparation Works

Vegetation plays an important role in cohesively binding soil particles and preventing
displacement. The removal of secondary vegetation and associated undergrowth will
result in exposed, denuded soil which will result in erosion of, especially during
heavy rainfall events.

The subject site was cleared and filled for industrial use in the mid 90s. Impacts
associated to soil erosion occurred at the time of land preparation and over the years,
the erosion potential of the site has declined. Clearing of the sparse vegetation within
the site is not expected to result in significant erosion.

However, subsequent earthworks which involve excavation, backfilling, grading,
laying of infrastructural facilities and other related activities will have a potential to
expose the soil to erosion. Generally, the susceptibility of any land surface to erosion,
i.e. the erosion potential is related to a combination of factors including rainfall,
runoff, soil erodibility, surface hydrology, surface slope and length, surface cover and
condition, and land use.

b. Construction Runoff and Drainage

Surface runoff and drainage from material stockpiles areas, excavated areas and
temporary drainage channels contain increased sediments and other water quality
contaminants. Potential contaminations include:

Grouting and other wet building materials;
Various types of lube oil, spent/waste oil and residues from construction
equipment, vehicles and diesel generators;
Residues and waste of industrial paints, pigments, lacquers, curing compounds,
etc;

5-8

Debris and rubbish such as packaging material, plastics, reject construction
materials and discarded containers ; and
Spillages of fuel oil (diesel), liquid chemicals, paints and other liquid waste
residues.

c. Sewage Effluent and Domestic Wastewaters

During the construction phase, temporary accommodation facilities may need to be
set up on-site to house the construction workers. Wastewaters generated will be in the
form of sewage effluent and domestic wastewater. During the construction phase,
preceding the building of the operating sewage system, the waste sewage generated
will be collected and removed from site from the interim septic tank systems.

5.2.2.2 Assessment of Impacts

The impacts to water quality during the construction phase can be categorised as
physical, chemical or biological impacts.

Physical Impacts: The most significant physical impact to water quality is an
increase in the level of suspended solids. The degree of the impact is determined by
the amount of material put into suspension and the size of the sediments. Extremely
fine particles such as clay and silt will go into suspension during excavation works,
and remain this way for a longer period compared to coarse-grained particles that
settle fairly quickly. Increased suspended solid levels will lead to a reduction in light
penetration and increase heat retention within the water column.

Chemical Impacts: Chemical impacts result from the release of toxic metals and
complex organic compounds or materials in the construction runoff and contaminated
sediment in the eroded soils that have an oxygen demand. These effects are a function
of the degree of sediment contamination. Contaminants found in the soil will
subsequently be ingested by organisms living within the water column and thus
introduced into the food chain. The presence of suspended solids in the water column
will reduce sunlight penetration which results in a lower rate of photosynthesis within
the water body. This will result in lower oxygen concentration in the water (lower
dissolved levels). Increase concentrations of SS will also trap energy from sunlight,
giving rise to the water temperature. This also acts against oxygen levels as oxygen is
more soluble in colder waters.

Biological Impacts: In general, biological impacts occur as a consequent of
chemical changes in the water. As discussed, the increase in suspended solid levels
will result in decreased photosynthesis rates within the water column thereby reducing
the concentration of dissolved oxygen. This effect may be further exacerbated during
low flow conditions. These conditions will effect the horizontal and vertical
distribution of bacteria and fungi in the water body. As for the larger marine life, low
oxygen levels may result in fish kills.

5-9

The increased sediment content in the water column may cause abrasion of gill
filaments and clog opercular cavities of aquatic organisms. The fresh water cage
cultures located along the western and eastern river banks of Sg. Chukai downstream
of the site may potentially be affected by the increased sediment loading into the
river.

a. Site Preparation Works and Construction Runoff/Drainage

The removal of the sparse vegetation within the site is not anticipated to cause
significant soil erosion. However, uncontrolled earthworks including excavation,
backfilling, grading, laying of infrastructural facilities and other related activities will
continue to expose the soil to erosion. These activities will require proper
management to minimise the washout of silt and sediment into the earth drain which
runs along the southern boundary of the site and flows in a westerly direction into
Sungai Balok.

Earthwork details including cut and fill quantities and the Road and Drainage Layouts
for the construction phase will be submitted to DOE Pahang prior to the
commencement of work at the site, i.e. as part of the Environmental Management
Plan (Construction Phase).

The site drainage layout plan for the construction phase presented in Exhibit 5.2.1
indicates the existing drainage channels at the site, the temporary earth drains
proposed during the construction phase and the location of the wash trough and the
silt trap. To minimise cut and fill impacts, the silt trap will be excavated at the area
proposed for the stormwater detention pond (operational phase). Based on the site
drainage plan, all surface runoff will be conveyed to a silt trap located on the
southwestern corner of the site for the removal of soil and sediment. The silt trap will
be sized adequately to cater for run-off from the works area. The plan and cross
sectional view of the silt trap and the earth drain are presented in Exhibit 5.2.2. The
clear overflow from the silt trap will flow from its outlet into the existing earth drain
which runs outside the sites southern boundary. This drain which is part of the
drainage network of the GIE flows into Sungai Balok, west of the site. A wash trough
has been proposed at the entrance of the main access road (refer Exhibits 5.2.1 and
5.2.3). The design of the site drainage is based on a 100 year flood event.

With these measures in place, the site preparatory works are not expected to result in
adverse erosion potentials. The impacts arising are transient in nature, occurring only
during the site preparation stage of the construction phase. The impacts to the water
quality of Sungai Balok are therefore not significant. With the effective
implementation of these measures, this risk will be further reduced.

5-10

b. Construction Runoff and Drainage

Water quality impacts from site drainage will become significant in the event the
runoff is uncontrolled and permitted to discharge directly into Sungai Balok without
any form of pre-treatment. Temporary and/or permanent drainage conveyance
systems will be installed immediately following the site preparation works. Provided
the construction runoff and drainage are effectively managed and controlled with the
implementation of the recommended mitigation measures described under Section
5.2.3, the impacts to the river is not predicted to be significant.

c. Sewage Effluent and Domestic Wastewaters

Untreated or inadequately treated sewage effluent and domestic wastewaters which
are high in organic content will increase the Biological Oxygen Demand (BOD) and
Ammoniacal Nitrogen (AN) concentration in the receiving waterways. These
effluents will also have high counts of faecal coliform, Escherichia coli and other
disease carrying bacteria.

To eliminate this source of pollution, portable toilets will be provided for use at the
proposed site to prevent any release of untreated sewage into the earth drain.

5.2.2.3 Mitigation Measures

Major water quality impacts anticipated from the construction phase are related to soil
erosion, sediment runoff and contaminated construction runoff. In mitigation,
measures must be taken during the site clearing and excavation works to ensure that
all losses of material to the receiving drainage channels are minimised.

Upon the onset of physical works, it is important that the nominated EPCM
Contractor be guided in the approach and planning of site clearance and earthworks.
Earthwork plans and phasing details complete with the relevant mitigating measures
will be submitted to the Local Authority for approval before the commencement of
works. It is recommended that an Erosion and Sedimentation Control Plan (ESC) be
integrated into the earthworks plan; and that the Contractor at all times comply with
the details of the plan.

An ESC plan is a document that explains and illustrates the measures to be taken to
control erosion and sedimentation during construction. Typically, an ESC includes the
following:

Description of predominant soil types within the affected area;
Details of site topography including existing and proposed levels;
Design details and locations for structural controls;
Details of temporary and permanent stabilisation measures; and
Description of the sequence of construction.

5-11

The ESC plans ensure that provisions for control measures are incorporated into the
site planning stage of development and provide for the reduction of erosion and
sediment problems.

Given below are general guidelines for non-structural and structural erosion control
measures that should be incorporated in the ESC plan and enforced during the
construction phase. The effectiveness of the ESC plan can be evaluated during the
implementation of the Environmental Management Plan (EMP) which includes
regular monitoring and audits.

. a. Earthworks

All temporary discharge points required in the earthworks will be located,
designed and constructed in a manner that will minimise the potential threat of
downstream flooding.

Any disturbed earth caused by construction activities or fill operations must be
firmly consolidated and compacted by earth moving vehicles and compactors to
reduce the rate of possible erosion and release of loose soil particles

Denuded stretches must be re-vegetated or sealed immediately after the
construction works. Suitable re-vegetation programmes employing leguminous
creepers, which are native grass that require minimal or no maintenance, should
be planted as quickly as possible on exposed areas as a temporary measure to
reduce surface runoff and sediment loss. Species such as Pueraria javanica,
Pueraria phaseoloides, Centrosema pubescens and Calopogonium muconoides
may be used for this purpose.

Uncovered stockpiles of excavated material or topsoil and fill material are prone
to erosion and therefore must be protected. Small stockpiles can be covered with
plastic sheets and large stockpiles should be stabilised by erosion blankets and
regularly damped.

Stockpiles of construction aggregate, spoil and excavated soil should be located at
areas within the project site that do not permit direct run off into water courses
and are generally flat. On site storage of excessive quantities of such materials
should be avoided.

c. Sediment Retention Structures

Sediment retention structures such as silt traps and settling basins of adequate
sizes should be provided at suitable locations prior to discharge into the receiving
drainage channels. One silt trap has been proposed at the southwestern corner of
the site as indicated in the site drainage layout plan presented in Exhibit 5.2.1.
Details of the silt trap design are presented in Exhibit 5.2.2. The location of the silt
trap is tentative pending approval from the Local Authority. Once the layout is
confirmed, the silt trap will be sized accordingly.

5-12

The proposed silt trap will be regularly maintained and desilted to provide
maximum silt removal efficiencies. Oil and grease removal facilities will also be
provided to ensure the overflow from the silt trap does not have traces of oil and
grease. Weekly inspection of silt trap will be carried out by the Contractor.

d. Others

The contractor will ensure that site management is optimised and that any solid
materials, debris, litter or wastes are not indiscriminately dumped on site or
disposed of in the existing unlined drains in the vicinity of the site or on other
unoccupied plots within the GIE. Appropriate waste receptacles will be provided
and periodic removal of any accumulated waste from the site should be arranged.

Sewage effluent generated from the workers camps will be treated prior to
discharge. Portable treatment units certified by the Department of Sewerage
Services are available which treat the effluent to meet the Standard B limits.

5.2.3 Operational Phase


In the operational phase of the project, the primary source of wastewater is the
Cracking & Separation Plant. The wastewater generated will arise from the upstream
extraction, downstream extraction, and product finishing processes of the plant.

Other forms of wastewater and contaminated streams generated from the plant
operations include:

Supernatant liquors and surface runoff associated with the Residue Storage
Facility (RSF);
Waste gas treatment system blowdown;
Discharge of water (drain-off) from the cooling towers;
Boiler blowdown;
Contaminated stormwater collected from bunded areas within the plant, namely
the reagent storage tank bunded areas;
Floor cleaning waters; and
Sewage and domestic wastewaters.

All wastestreams and liquor (if not recycled in the process) from the plant operations
identified above will be treated within the Wastewater Treatment Plant (WWTP) (bio-
treatment plant) and the treated effluent will be conveyed to clears for further
polishing. (The wastewaters from the Cracking and Separation Plant will be pre-
treated via a neutralization process within the High Density Sludge (HDS) system
prior to entering the WWTP).

5-13

From the clear wells, the treated wastewater will be pumped into the stormwater
detention pond which discharges into an external earth drain running along the
southern boundary of the site. The drain flows into Sungai Balok which flows in a
southerly direction some 3 km west of the site.

a. Liquor and Potentially Contaminated Surface Runoff from the TSF

Surface water runoff (including rainfall runoff) and supernatant liquor from the RSF
will be segregated from the main plant site drainage system and managed separately.
This is to ensure that these sources of water pollution do not mix with uncontaminated
surface water from other parts of the plant site. Any supernatant liquors and surface
runoff associated with RSF cells will be conveyed to dedicated RSF retention ponds
prior to return to the waste water treatment facility (WWTF), or to the cracking and
separation process in the case of the WLP storage cells.

During the operational phase, the surface of active FGD, NUF and WLP residue
containment cells will be continuously contoured by earthmoving equipment to a
slope of approximately 100H:1V as the residue are placed within the respective cells.
The residue will then be compacted to direct surface water towards a single
supernatant/surface runoff retention pond within the RSF cells. The FGD and NUF
cells will share a common pond whilst the WLP containment cell will have a separate
dedicated retention pond due to its physio-chemical properties.

The retention ponds will be lined with high density polyethylene (HDPE) and the
capacity designed to cater for the 1 in 100 year storm event based on climatic data for
the region. Water from this pond will be discharged to the nearest pipeline access
point for return to the Wastewater Treatment Plant (WWTP) located within the plant
process area.

The composition of surface water runoff and supernatant liquors from the WLP
residue is not expected to be suitable for release back into the environment. Instead
this water stream will be recycled into the cracking and separation process stream and
as such, surface water runoff will be directed or pumped to a separate HDPE-lined
surface water retention pond with capacity for the 1 in 100 year storm event based on
climatic data for the region. From the retention pond, the effluent will be pumped via
pipeline to the nearest pipeline access point for return to the cracking and separation
facility.

At closure, residue cells will be capped with suitable low-permeability materials to
prevent infiltration into the permanently stored residue mass and a landform will have
been created with positive surface drainage. Surface water runoff from capped cells
will not interact with stored residue and the final site topography will encourage
surface water to drain off-site to prevent ponding and standing water.

5-14

b. Cooling Tower Drain-Off and Boiler Blowdown

The drain-off from the cooling towers and the boiler blowdown will be pumped to the
WWTP. Potentially contaminated runoff collected within the reagent storage bunded
areas (acid and alkali storage farm) will be either pumped out or conveyed directly via
pipelines to the sites WWTP. Similarly, floor cleaning waters arising from the
Cracking & Separation Plant, if contaminated with process liquor will be conveyed to
the wastewater treatment system. Cleaning waters from other non-polluting areas of
the site will be conveyed into the sites stormwater drainage system.

c. Sewage and Domestic Wastewaters

The maximum number of operations personnel on-site during normal working hours
(0800 1700) is expected to be 200, with 50% of the personnel based in the field
control rooms. The central administration area (with adjacent buildings for laboratory,
canteen, maintenance and stores) will have toilets piped to the on-site sewage
treatment system (aerobic sludge system) which will be designed for a minimum
Population Equivalent (P.E) of 200. The remote control rooms will have local septic
tanks. The treated water from the sewage treatment plant will be conveyed to the
sites main treatment plant.


All waste streams and liquor (if not recycled in the process) from the Advanced
Materials Plant operations identified above will be treated prior to discharge into
Sungai Balok.

Two treatment systems, i.e. the High Sludge System (HDS) and the WWTP (bio
treatment plant) have been proposed for the plant operations. The HDS system is
essentially a neutralisation pre-treatment process for the wastewaters from the
Cracking & Separation Plant. Details of the treatment process are discussed in Section
5.2.3.3.

All other process waste streams and contaminated streams will enter the WWTP
directly without any pre-treatment. Sewage and sanitary wastewaters will be routed to
a Sewage Treatment Plant and the treated discharge will pumped into the WWTP. The
wastewater block flow diagram presented in Exhibit 5.2.4 identifies the major
sources of waste streams and their inflow into the HDS and the WWTP.

The final treated effluent from the WWTP will be held in clear wells and then
pumped into the stormwater detention pond (at an average rate of 500 m
3
/hr) and the
combined discharge will be released into the earth drain (external to the sites
southern boundary) which flows into Sungai Balok.

5-15

The untreated waste streams entering the HDS process and WWTP identified in the
section above will contain the following chemical species:

Suspended solids (SS)
NH3-N
Phosphate
Cations: Low concentrations of Cu, Zn, Mn, Cl, Hg, As, Pb, Cr, Th, Mg, Sr,
U, Ca, Al, Si, K, Ba, Fe, Na, K+Na
Calcium sulphate (CaSO
4
)
Magnesium sulphate (MgSO
4
)

If untreated, these waste streams will impact the Sungai Balok river quality in terms
of physical, biological and chemical impacts similar to those discussed under Section
5.2.2.2. To mitigate these affects, these waste streams will be subjected to treatment
within the HDS and the WWTP prior to discharge.

The impacts of discharging the treated effluent from the plant during the operational
phase have been assessed quantitatively to simulate the pollution loading to Sungai
Balok and predict the changes in water quality of the river with the added discharge of
the effluent from the Advanced Materials Plant.

a. Methodology

Access to hydrodynamic data related to the Sungai Balok is limited but simple
observations were made of the channel width and depth during the water quality
survey, along with estimates of flow. The survey locations are presented in the image
below.

5-16

The observations were made at high and low water. These flow measurements do not
indicate the peak flow values. However, for the purposes of water quality assessments
typical low flows in the river are more important rather than peak or flood flows.
Thus, information on flood flows was not critical for purposes of this study.

The tables below summarise the available hydrodynamic information. River channel
width and water depth information are presented in Table 5.2.3. Only one flow
velocity measurement was taken at each location during the survey and each
measurement was taken at about 0.5 m below the water surface in the middle of the
river. Therefore the velocities of the river flow that are presented in Table 5.2.4 are
very close to the maximum flow velocities and the average flow velocities are
expected to be in the order of 30%-50% of the measured velocities. Therefore, the
likely average river currents at high and low water are in the range 0.1 to 0.6 m/s.
There is no information on the variation of current speeds during ebb and flood.

5-17

Table 5.2.3: Water Depth and Channel Width at Survey Sites

High Tide Low Tide
Point Depth (m)
Estimated Top
Width (m)
Depth (m)
Comments
W1 5 30 3.4
W2 2 27 0.4
W3 2 10 0.5
W4 1.5 8 0.3
W5 8 15 6.9
W6 6 13 6 less tidal influence
W7 3 8 3 less tidal influence
*Note: The location of stations W1-W7 corresponds with the water quality monitoring stations
established for the baseline river water quality sampling. Refer Exhibit 4.14.

Table 5.2.4: Flows of Sungai Balok

Flow velocity (m/s)
Point High Tide Low Tide
W1 0.91 0.61
W2 0.61 0.85
W3 0.61 0.55
W4 0.46 0.30
W5 0.30 0.21
W6 0.55 0.30
W7 1.22 0.91

The low and high tide records obtained from the Kuantan Port Authority indicate that
the difference between high water and low water was 1.5 m. The typical tidal levels
at the mouth of Sungai Balok are expected to range from 0.5 m to 2.5 m (see Table
5.2.5).

Table 5.2.5: Tidal levels at the Sungai Balok Estuary (Tidal station at Tanjung
Gelang)

MHHW MLHW MHLW MLLW
3.34 m CD 2.28 m CD 1.57 m CD 0.5 m CD

b. Existing Water Quality of Sungai Balok

Based on the river water quality monitoring event carried out in October 2007 (refer
Section 4.6.4 of Chapter Four), the results show that the river is tidal as far as point
W7, with total dissolved solids (TDS) of 36 6,182 mg/l (low tide) and 28 12,990
mg/l (high tide). This indicates that the water is brackish.

At all locations, metal concentrations were below the detection limit and very much
lower than the Class III water quality standard. Most of the parameters analysed
complied with the Class II limits. The following metals were tested for in the river
samples arsenic, cadmium, copper, manganese, lead, nickel, tin and zinc.

5-18

The level of organic pollution can be inferred from the five day Biochemical Oxygen
Demand (BOD
5
) and the Chemical Oxygen Demand (COD). At stations W1 to W7,
the BOD
5
concentrations were < 2 mg/l while the COD value is in the range 25-65
mg/l (for both the tide cycles). The relationship between BOD
5
and COD is dependent
on the characteristics of the water body and its inputs; however such a large COD to
BOD
5
suggests that the river has low amounts biodegradable material, and hence
receives low amounts of organic pollution.

c. Quality of Treated Effluent Discharge

The characteristics of the treated effluent discharged from HDS Neutralisation system
is presented in Table 5.2.6. The effluent meets the Standard B discharge criteria
stipulated in the Environmental Quality (Sewage and Industrial Effluent) Regulations,
1978 except for COD which exceeds the limit of 100 mg.l.

Table 5.2.6: WWTP Treated Effluent Quality

Species HDS Neutralisation Wastewaters
mg/l
Malaysian Standards B
mg/l
pH 5.5-9
SS 100 mg/l 100
COD 2000 100
BOD
5
- 50
oils 50
Cu < 1 1.0
Zn 0.462 2
Mn < 1 1.0
Cd - 0.02
Hg - 0.05
As - 0.1
Pb 0.07 0.5
Sn < 1 1.0
B - 4.0
Cr - 0.05, 1
Fe < 1 5.0
Phenol - 1.0
S 496 0.5

The treated water from the HDS system is stored in the then conveyed to the WWTP
(Sequential Batch Reactors) for COD reduction. The WWTP has been designed to
treat up to a maximum of 2000 mg/l. It should be noted that this point that the quality
of the wastewater from the HDS neutralisation (pre-treatment) process complies with
Standard B for all the heavy metals and total suspended solids. Only the COD
concentration exceeds the limit.

5-19

From the WWTP, the treated water will be discharged at an average flow rate 500
m
3
/hr into the stormwater detention pond. Prior to discharge into the detention pond,
the treated water is allowed to settle in clear wells/surge ponds where samples will be
collected for analysis. The water will be pumped into the detention pond only when
all parameters stipulated in Standard B are complied with.

d. Approach and Methodology

Ideally, the impact of the discharge on water quality in the river would be assessed by
constructing a one-dimensional model of the river. However, even a very approximate
model of the system would require a reasonable amount of data relating to river cross-
sections, downstream water levels and upstream river flows.

Given the limitations in the data, a different approach was adopted using a mass
balance model based on the likely combined flows from the stormwater detention
pond into the drain and hence into the river. The basic assumptions are:

The discharge from the detention pond is constant for a given rainfall event;

The quality of the stormwater can be estimated using event mean concentrations
from literature;

The treated effluent from the WWTP is fully mixed with any storm water in the
retention pond;

Little or no other flow enters the external earth drain;

The discharge from the storm drain is fully mixed through the water column and
across the width of the river channel; and

That the river flow in Sungai Balok is of the order of 20 m
3
/s and that the tidal
currents in the section of the river are weak, so that the bulk of the dilution of any
effluent is due to freshwater river flow.

e. Stormwater Discharges

Stormwater runoff from the site is to be collected in a detention pond before being
discharged to the storm drain, and then to Sg Balok. Stormwater discharges to the
pond provided by the engineering designers as follows:

For 5 year ARI - Average stormwater inflow into detention pond (5.56 m
3
/s),
peak outflow from detention pond (6.64 m
3
/s)

For 50 year ARI - Average inflow into detention pond (8.80 m
3
/s), peak outflow
from detention pond (10.45 m
3
/s)

5-20

For 100 year ARI - Average inflow into detention pond (9.94 m
3
/s), peak outflow
from detention pond (11.56 m
3
/s)

In addition, the average inflow for a typical period of low rainfall was calculated.
Assuming an average rainfall of 17.6mm, the average inflow into the detention
pond would be 2.03m
3
/s.

(*Note: ARI: Average Recurrence Interval)

f. Stormwater Quality

The water quality of storm water discharging into a drain or river largely depends on
the use of the land from which storm water runs off. The load of pollutant washed off
the land by stormwater is usually determined using the Event Mean Concentration
(EMC) methodology. This assumes that the load of a particular pollutant can be
determined from a representative mean concentration likely to be achieved during a
rainfall event. The load is simply the product of the runoff, the catchment area and the
EMC. The value of this EMC depends on the use of the land. Various bodies
including the Department of Irrigation and Drainage (DID) of Malaysia quote
guideline values to be used to estimate stormwater loads. Table 5.2.7 provides a
summary of EMC values derived from US and European sources.

Table 5.2.7: Summary of Event Mean Concentrations (EMC)

Pollutant
EMC-Industrial
land use (mg/l)
EMC-
Agriculture
with
significant
vegetation
land use (mg/l)
EMC-Urban
Land use
(mg/l)
EMC- Bare
land use
(mg/l)
BOD 29 0 8.3 6
COD 120 0 70 23
SS 159. 12.7 55 42.5
TN 2.0 2.8 3.2 1.5
NOx-N 0.5 0 0.4 1.3
NH3-N 0.1 0 0.2 0.2
TKN 1.8 0 0.9 0.9
TP 0.3 1.5 0.34 0.16
Cd 0 0 0.0024 0
Cu 0.05 0 0.0036 0.09
Fe 4.6 0 4.6 0
Pb 0.12 0 0.16 0.03
Zn 0.25 0 0.19 0.07

Note: Compiled from 1.Urban and Road Specific Event Mean Concentrations (Mitchell 2001), 2. US EPA. 1993c,
Handbook Urban Runoff Pollution Prevention and Control Planning. EPA 625-R-93-004. Washington, DC., 3.
Recognized Event Mean Concentration, (www.sfrpc.com/ftp/pub/watershed/swakon%20tables%20formatted.pdf).


5-21

The draft of the Urban Stormwater Management Manual for Malaysia (Manual
Saliran Mesra Alam Malaysia (MSMA)) (DID, 2001)
3
gives guideline values for
EMC for a selection of variables (Table 8). However, the MSMA table does not give
values for COD and gives a wide range of values for other parameters for runoff from
industrial land. For the purpose of the analysis the values for industrial land in Table
5.2.8 were used.

3
Table 15.2, Manual Saliran Mesra Alam Malaysia, Department of Drainage and Irrigation, Malaysia (2001)


5-22

Table 5.2.8 Typical Event Mean concentration values (EMC) from MSMA

g. Results and Discussion

Using the assumptions laid out in Section 3.1, the likely impact of the plant effluent
on the river was estimated for two plant treatment options and three rainfall
conditions.

The two plant treatment operations are:

Normal Operation : Full treatment, average effluent flow of 500 m
3
/hr
Treatment plant failure - No treatment , maximum effluent flow of 700 m
3
/hr

The three rainfall conditions considered are:

No rainfall
Low rainfall ( based on average daily rainfall of 17.6 mm)
5 year ARI

The river quality was based on that observed at site W6 on 31st October 2007.

5-23

The plant effluent is expected to be brackish with sodium and chloride concentrations
of 1360 mg/l and 5197 mg/l respectively. This effluent will be denser than either the
storm water or the river water. At W6, the observed TDS was < 500 mg/l (based on
the baseline environmental sampling). The assumption is made that there will be
sufficient mixing in the river or retention such that any density difference does not
significantly affect the fate of the effluent.

The analysis was carried out for five parameters:

TSS
COD
BOD
Zn
Pb

The choice of parameters was limited by the plant effluent data, the availability of
appropriate EMC values for the stormwater, parameters analysed in the river samples
and parameters for which are included in the river quality standards. For the untreated
case the NH
3
-N was added.

The base case of normal operation during the period of no rainfall is shown in Table
5.2.9. This shows that for the parameters tested, the effluent has little impact on the
river water quality as the effluent will be diluted by a factor of at least 150 when fully
mixed with the river water. It should be noted that the COD observed on 31st
October 2007 at site W6 (51-55mg/l) was already in excess of the River Water
Quality Standard (Class III) value (50mg/l). However, the secondary data obtained
from Alam Sekitar Malaysia (ASMA) samples in 2007 show lower COD values in Sg
Balok (16-23 mg/l) than were measured in any of the samples collected for the EIA
study. Therefore, it is likely that under these conditions the effluent will not cause the
river water quality to exceed the standard values.

Table 5.2.9: Normal operation with No Rainfall

Species Treated
effluent
Storm
water
Effluent from
detention
pond
River
upstream
River down
stream
River WQ
Standard III
Q m
3
/s 0.14 0 0.14 20 20.2 -
TSS mg/l 50 - 50 2.5 2.8 150
COD mg/l 100 - 100 51 51.3 50
BOD mg/l 50 - 50 2 2.3 6
Zn mg/l 0.462 - 0.462 0.012 0.02 0.4
Pb mg/l 0.07 - 0.07 0.01 0.01 0.02

In the presence of low rainfall, the concentrations of all parameters are increased
(Table 5.2.10). This is mainly because the EMC values used for the storm water are
in excess of the treated effluent concentrations. Therefore, the storm water is the
major contributor to any increase in river concentrations.


5-24

Table 5.2.10: Normal Operation in Low Rainfall Period

Species Treated
effluent
Storm
water
Effluent
from
detention
pond
River
upstream
River
down
stream
River WQ
Standard
III
Q m
3
/s 0.14 2 2.2 20 22 -
TSS mg/l 50 160 152.9 2.5 17.03 150
COD mg/l 100 120 118.7 51 57.54 50
BOD mg/l 50 29 30.4 2 4.75 6
Zn mg/l 0.462 0.23 0.25 0.012 0.04 0.4
Pb mg/l 0.07 0.12 0.12 0.01 0.02 0.02

As the stormwater flow rate increases by increasing rainfall, the combined impact of
the treated effluent and site stormwater increases (Table 5.2.11) in the 5 year ARI
rainfall scenario. There is a risk that the combined effluent will cause the river quality
to marginally exceed the water quality standard for COD, Zn and Pb.

Table 5.2.11: Normal Operation with 5 year ARI Rainfall

Species Treated
effluent
Storm
water
Effluent
from
detention
pond
River
upstream
River
down
stream
River WQ
Standard
III
Q m
3
/s 0.14 5.56 5.7 20 26 -
TSS mg/l 50 160 157.3 2.5 36.8 150
COD mg/l 100 120 119.5 51 66.2 50
BOD mg/l 50 29 29.5 2 8.1 6
Zn mg/l 0.462 0.23 0.24 0.012 0.07 0.4
Pb mg/l 0.07 0.12 0.12 0.01 0.03 0.02

In the case of the release of untreated effluent in the dry period the effluent
concentrations will be significantly higher than with the treated effluent. For the
analysis, the maximum COD of 2000mg/l was assumed. Despite the high
concentrations, the effluent flow is small compared to the river flow, and the effluent
will undergo significant dilution in the river. The resulting river concentrations will be
higher than those experienced in similar conditions with treated effluent. With no
rainfall, the contribution of the plant effluent is small with the exception of COD,
which could be increased by up to 25-30% (Table 5.2.12). However, as there is some
uncertainty as to the typical COD concentration in the river, this may not be lead to a
concentration in excess of the river quality standard.


5-25

Table 5.2.12: Releasing of Untreated Effluent with No Rainfall (Worst Case Scenario)

Species Untreated
effluent
Storm
water
Effluent
from
detention
pond
River
upstream
River
down
stream
River WQ
Standard
III
Q m
3
/s 0.19 0 0.19 20 20.2 -
TSS mg/l 100 - 100 2.5 3.1 150
COD mg/l 2000 - 2000 51 64.4 50
BOD mg/l 82 - 82 2 2.6 6
NH
3
-N
mg/l 1.3 - 1.3 0.1 0.11 0.5
Zn mg/l 0.462 - 0.462 0.012 0.02 0.4
Pb mg/l 0.07 - 0.07 0.01 0.01 0.02

As contribution from stormwater is increased, then the impact of the combined
effluent on the river increases (Tables 5.2.13 and 5.2.14). The contribution of the
stormwater can be as significant as the untreated storm water particularly for BOD.

Table 5.2.13: Release of Untreated Effluent in Low Rainfall Period

Species Untreated
effluent
Storm
water
Effluent from
detention pond
River
upstream
River
down
stream
River WQ
Standard
III
Q m
3
/s 0.19 2 2.2 20 22 -
TSS mg/l 100 160 154.7 2.5 17.6 150
COD mg/l 2000 120 286.6 51 74.3 50
NH
3
-N
mg/l 1.3 0.1 0.21 0.1 0.11 0.5
BOD mg/l 82 29 33.7 2 5.1 6
Zn mg/l 0.462 0.23 0.25 0.012 0.04 0.4
Pb mg/l 0.07 0.12 0.12 0.01 0.02 0.02

Table 5.2.14: Release of Untreated Effluent with 5 year ARI Rainfall

Species Untreated
effluent
Storm
water
Effluent
from
detention
pond
River
upstream
River down
stream
River WQ
Standard
III
Q m
3
/s 0.19 5.56 5.75 20 22 -
TSS mg/l 100 160 158.0 2.5 37.2 150
COD mg/l 2000 120 183.53 51 80.6 50
BOD mg/l 82 29 30.8 2 8.4 6
NH
3
-N mg/l 1.3 0.1 0.14 0.1 0.11 0.5
Zn mg/l 0.462 0.23 0.24 0.012 0.07 0.4
Pb mg/l 0.07 0.12 0.12 0.01 0.03 0.02


5-26

h. Conclusions

A quantitative analysis of the mixing of the plant effluent with storm water from the
site before discharging in to the river has lead to the following conclusions:

Discharge rate of the WWTP treated effluent is very low compared to likely
storm water and river flow rates;

The impact of treated effluent alone on river quality is very low, and is likely to
be diluted by a factor of 150 by the river water.

The contribution of storm water runoff from the site to river impact could be
more significant than from the plant effluent.

Discharging untreated effluent to the river will worsen river water quality. The
COD concentration could be increased by up to 30% but this impact is expected
to be only short term. It should also be noted that existing COD in the river
system is greater than 50mg/l as per Class III water quality standard. If there is a
desire to improve the water quality of Sungai Balok further then there needs to be
consideration of all discharges into the river system rather than considering only
one point source such as the Advanced Materials Plant.

The conclusions drawn from the analysis are subject to the following limitations

Sg Balok river flows are unknown;
Other pollution loading into external earth stormwater drain is not
quantified; and
Uncertainty in EMC values.

5.2.3.3 Recommended Mitigation Measures

The water quality assessment described in the section above assumes that the effluent
is treated by the WWTP and meets the Standard B discharge quality with an average
discharge flow rate of 500 m
3
/hr. Therefore, it is critical that all the major waste
streams are treated within the proposed treatment systems proposed, i.e. the HDS and
the WWTP and these systems are well maintained and in good working order at all
times.

5-27

A description of the proposed treatment systems is provided below.

a. High Density Sludge (HDS) System

The waste water from the cracking plant will undergo pre-treatment prior to entering
the main WWTP. HDS is a process used to treat acidic process wastewater from
Cracking and Separation, which contains Cl
-
, SO
4

2-
and metal ions such as iron,
aluminium, manganese, sodium, magnesium, calcium, etc. Neutralization and
precipitation takes place at pH 10.5 to reduce the concentration of metal ions to the
required levels.

Milk of lime is produced from powdered hydrated lime in two agitated 3600
3000 mm agitated slurry tanks. The acidic wastewater generated from the scrubber
is stored in 2 x 4500 4500 mm tanks prior to treatment.

The milk of lime is mixed with the wastewater and then sent to a reaction zone,
where neutralization followed by chemical precipitation takes place. At a reaction
end point pH of 10.5, most of the metal ions have been precipitated. The
wastewater neutralization tank is divided into three zones, the first provided with
high speed agitators to ensure rapid mixing and the last with low speed agitators to
allow slow (complete) reaction. The size of each zone is 450045003000mm.

The neutralised wastewater slurry flows to a thickener which separates the
supernatant from the solids which contain the metals and calcium sulphate. The
supernatant overflows from the top of the thickener, and is pumped to the WWTP.

The thickener underflow is processed in 4 plate and frame filter presses to produce
a filter cake Neutralised Underflow Residue (NUF) of approximately 30-40%
moisture which will be stored in the NUF tailings storage facility (RSF). The
filtrate may either be returned to the HDS inlet or sent to the WWTP. The plate
and frame filter presses will also dewater the FGD slurry independently of the
NUF solids, producing a filter cake of approx 30-40% moisture for placement into
the FGD RSF.

b. Wastewater Treatment Plant (WWTP)

The Wastewater Treatment Plant employs a is a biotreatment process and has been
designed primarily to reduce COD and BOD in all the wastewater streams from the
plant and to produce water complying with Malaysian water quality Standard B. The
WWTP will consist of the following steps as necessary to achieve the standard.

Inlet neutralisation and storage
BOD/COD reduction
Settling and clarification
Sludge processing

5-28

Wastewater exit.

Inlet Neutralisation & Storage

The treatment/equipment proposed may consist of the following:

1. Receiving and blending incoming streams to minimise quality variations.
2. pH adjustment/chemical dosing

Aeration and oxidant dosing

The process proposed combines biological oxidation with final reduction using a
strong oxidant as necessary. The treatment/equipment proposed may consist of the
following:

1. Aeration for first stage (biological) treatment
2. The use of surface aerators or diffusers is being considered.
3. Treatment with strong oxidant dosing (hydrogen peroxide)

Flocculation and Settling

Flocculation followed by settling and sludge removal is proposed. The use of a
Lamella clarifier is being considered. The treatment/equipment proposed may consist
of the following

1. Dosing of flocculent and coagulant
2. Mixing
3. Sludge/supernatant separation (thickening)
4. Sludge removal

Sludge Processing

A fabric bag collection and disposal system is proposed. Large Geotextile fabric bags
are often used in the mineral processing industry and are considered to be an
economic solution. Three x 3 m diameter x 25 m long bags annually may be used. A
typical treatment/equipment consists of the following stages:

1. Preparation of sludge (addition of flocculent)
2. Filling of Geotextile bag #1 with sludge.
3. Filling of Geotextile bag No 2 with sludge while liquor drains from bag No. 1
(bag draining)

5-29

4. Disposal of liquor (recycle to WWTP).
5. Repeat of steps 2 and 3 until bags are filled with high solids and no further space
remains after drainage.

6. Open bag and dry/dispose solids.

The usual practice is for three bags to be in operation located and contained in an
(impervious) kerbed area. One bag is being filled, one draining/drying and one in
disposal. Disposal is by cutting open the bag and removing the sludge. About 100
200 tons/year of sludge is expected which is disposed to the WLP RSF. Flocculent
may be added to assist in the draining of the liquor from the sludge. No further
treatment of the sludge prior to fabric bag collection is required. Options of filters and
a centrifuge were considered but discarded.

Wastewater Storage and Exit

The clarified wastewater will be sent to clear wells/surge ponds prior to discharge to
the stormwater detention pond.

Water Recycling

Maximum use has been made of recycled water within the Cracking and Separation
Plant. The liquor entrapped within the RSF for the Water Leach Purification (WLP)
residue will be collected and recycled to the Water Leach circuit (Cracking &
Separation Plant). It is possible that liquor entrapped within the RSF Facility for the
NUF & FGD will also be recycled into the Water Leach circuit.

Waste Water Testing

In order to estimate the composition of the various wastewater streams produced from
the Cracking & Separation Plant, the following testwork has been undertaken:

The Cracking and Separation Plant wastewater data used in the modelling has been
built-up from in-house Lynas operational experience and a pilot study carried out
by the wastewater treatment plant consultant which has been verified by testwork
conducted by Australian Nuclear Science Technology Organisation (ANSTO).

5-30

5.3 SOIL AND GROUNDWATER


The Environmental Quality Act, 1974 (EQA) and amendments provide for the
protection of soil, and indirectly groundwater, under Section 24. This section broadly
states that no person shall, unless licensed, pollute or cause or permit to be polluted
any soil or surface of any land in contravention of the acceptable conditions specified
under Section 21. The acceptable conditions, however, have not been defined in
the regulations.

At present, there are no formal or enforceable standards in Malaysia for evaluating
soil and groundwater quality. As such, suitable soil and groundwater investigation
criteria for comparing with measured site concentrations were selected from sources
established in other countries. The Dutch Ministry of Housing, Spatial Planning and
Environments (MVROM) soil and groundwater quality guideline values have been
prescribed in several environmental impact assessments (EIA) guidance documents
published by the DOE for use in assessing soil and groundwater quality.



Impacts on soil and groundwater quality during the construction phase are commonly
attributed to improper management and handling of hazardous materials stored at the
site. Potential sources of soil and groundwater quality impacts include:

Accidental spillage and leakage arising from the handling and storage of
hazardous materials/chemicals in diesel skid tanks, chemical/fuel dispensers and
storage drums, jerry cans or carboys that contain lube oil, hydraulic oil, paints and
organic solvents and other chemicals used during the construction phase;

Leakage arising from vehicle engine oil change, equipment and machinery, as
well as refueling activities;

Inappropriate hazardous waste storage and disposal practices;

Improper discharge of untreated sewage; and

Groundwater dewatering activity.

5-31


Soil and groundwater impacts arising from accidental spillage and leakage of
hazardous chemicals and wastes during the construction phase are assessed to be low
due to the limited quantities of chemicals used at any one time on-site during
construction. In addition, the extent of soil and groundwater contamination is likely to
be localized and surficial. These impacts can be readily addressed by implementing
appropriate mitigation measures discussed in the proceeding section.

Groundwater pumping may be required where foundation excavations extend below
static water levels. Such dewatering may be required for some refinery foundations.
However, the need for significant groundwater discharge is unlikely. In the unlikely
event that some dewatering is required, the extracted water will be conveyed via the
silt trap proposed for the construction works area prior to discharge into the sites
drainage system.


The risks of soil and groundwater contamination during the construction phase will be
appropriately managed and controlled by the following:

A secured area (enclosed with hardstanding imprevious base) will be provided for
the storage of any hazardous materials (including hazardous wastes);

All temporary fuel tanks and drum storage areas will be provided with drip
collection devices and be sited on sealed areas (for example, concrete paved
areas) with appropriate bunding for accidental spill containment. A valve should
be installed at the discharge outlet of the bunded area;

All activities that may result in the potential release of hazardous materials to the
ground such as changing of engine oils and lubrication oils from construction
vehicles, equipment and generators on site will be performed only on designated
sealed areas or on drip trays to reduce the risk of direct spill into the underlying
soil and groundwater. Spent oil must be handled and disposed of as scheduled
waste;

Any accidental spills of fuel, oil or other hazardous chemicals will be cleaned up
immediately. The recovered media (contaminated soil, absorbent pads, rags etc)
should be disposed of as scheduled waste; and

5-32

Appropriate sanitary facilities will be provided and properly maintained for
construction workers throughout the construction stage. Direct discharge of
untreated sewage into underlying soil, groundwater or surface water is prohibited.
If portable toilets are procured to the site, they must be of sufficient numbers and
meet the requirements of Department of Sewerage Services, Ministry of Housing
and Local Government.



The areas of concern for the potential soil and groundwater contamination during the
operational phase include:

Lanthanide Concentrate Storage Shed;
Residue Storage Facility (RSF);
WLP Retention Pond;
NUF and FGD Retention Pond;
Acid storage area (tank farm);
Chemical Store;
The 10,000-litre aboveground diesel storage tank;
The emergency firewater pumphouse (with 1,000-litre diesel storage tank);
Diesel generators (with 5,000 litre diesel storage tank each); and
Scheduled wastes (waste oil, expired chemicals, etc) storage area.

In addition, other potential sources of impact include the periodic handling and
dispensing of chemicals with the process areas, spills of fuels and lubricating oils,
albeit in small quantities, may lead to minor spills and leakages. Such accidental
releases are usually a result of poor chemical handling practices and may likely occur
at the maintenance workshop and hazardous substances handling and storage areas.


Accidental release of chemicals such as petroleum hydrocarbons, acids, reagents and
other chemicals (as described in Tables 2.2a and 2.2b in Chapter Two of this report)
have the potential to result in adverse impacts on soil and groundwater resources
during the operation of the plant.

5-33

Both organic and inorganic contaminants in soil and groundwater have the potential to
pose short term and long term threats to human health, safety and sensitive
environmental receptors. For example, the accumulation of volatile organic
compounds (VOCs) as a result of petroleum hydrocarbon spills into the underlying
soil and groundwater may reach explosive levels in subsurface utility systems, or the
concentrations of these vapours may cause acute health effects to facility and
maintenance workers.

Changes in pH from acid and chemical spills have the potential to affect
microorganisms in soil and groundwater and affect the natural soil processes such as
biodegradation.

Contaminants present in groundwater on-site have the propensity to migrate to
downgradient neighbouring properties and affect underlying aquifers or threaten
sensitive habitats in rivers. Excavation or construction workers may potentially be
exposed to these contaminants via dermal contact, inhalation of vapours or accidental
ingestion when carrying out sub-surface activities.

Groundwater contamination problems are also long-term in nature. Certain
contaminants are resistant to biodegradation and will persist in the environment for
many years after the source of contamination has been removed. The presence of
these residual contaminants in the soil and groundwater may pose an unacceptable
risk particularly if the land is to be redeveloped into a more sensitive land use such as
for residential or recreational purposes.

During the operational phase of the project, groundwater will not be abstracted for use
within the site. Potable water supply will be obtained from the Department of Water
Supply for use within the site. Thus, there will be no direct impacts on the local
groundwater system. However, there is potential to indirectly affect groundwater by
the seepage of contaminated water from the plant operations and the RSF.

The raw material for the plant which is the lanthanide concentrate will be stockpiled
within the lanthanide concentrate storage shed. The concentrate will arrive at the plant
site (from the Port of Kuantan) in sea containers. The concentrate will either be
bagged in bulker bags (1 tonne) or the entire container will be lined (20 tonnes). At
the site, the concentrate will be off-loaded from the containers and stockpiled within
the storage shed before it is loaded onto the hopper. The stockpile is not expected to
generate significant leachate. Further, the concentrate will be stored within a covered
shed for prevention of rainwater ingress and the ground paved to minimise impacts to
the groundwater.

Trace metals from the residue stored at the RSF has the potential to leach or to be
released into the underlying shallow groundwater if no appropriate containment is
provided. The assessment of soil and groundwater impacts arising from the RSF is
deliberated in the next section (Section 5.6.3).

5-34

Storage ponds within the site include the liquor containment ponds: WLP Retention
Pond, the NUF & FGD Retention Pond, and the Emergency Storage Lagoon. The
contents of the liquor ponds could potentially contain contaminants that could impact
the groundwater quality. To prevent the seepage of these contaminants into the soil
and groundwater, these ponds will be provided with a high density polyethylene
(HDPE) liner.

The entrapped liquor within the NUF and FGD pond will be removed and returned to
the nearest pipeline access point for return to the waste water treatment plant
(WWTP) within the process area. However, the liquor collected within the WLP pond
is not expected to be suitable for release into the environment and thus will be
recycled in the Cracking & Separation Plant. With the above safeguard measures, the
potential impacts to soil and groundwater resources can be effectively mitigated.

Based on groundwater level gauging data, groundwater gradient at the site is
calculated to be approximately 0.001. Single well falling head test data conducted in
selected monitoring wells indicated that hydraulic conductivity for the organic clay
layer and the underlying silty sand material were in the order of 10
-8
m/s and 10
-6
m/s
respectively. Based on an assumed preliminary conservative estimate of effective
porosity of 0.35, the seepage velocity or flow rate of the shallow groundwater beneath
the site is estimated at approximately 0.110 cm/year.

Data from the baseline groundwater gauging indicate that the shallow groundwater
beneath the site generally flows along a southerly direction. Given the relative low
seepage velocity in a silty/clayey soil media and the absence of potentially sensitive
groundwater receptors on site and immediately downgradient, the risks associated
with soil and groundwater contamination is anticipated to be low.

Impacts to soil and groundwater resources associated with plant operations could be
easily addressed, prevented and overcome by implementing appropriate mitigation
measures discussed in the following subsection.


The facilities should be designed and operated to ensure that as far as practicable,
leakage and accidental release of chemicals into the underlying soil and groundwater
do not occur. Prevention and control measures include the following:

The diesel fuel storage tank and reagent storage tanks will be located within
concrete-bunded enclosures capable of containing 110% of the contents of the
tank within each enclosure. The floor of the bunded enclosures will be concrete-
lined with an impermeable liner to prevent contaminant from permeating into the
ground;

5-35

Appropriate instrumentation and control/trigger alarm to warn of possible
overfilling and to provide an alert mechanism in the event of significant
fuel/chemical loss should be provided for the storage tanks;

Operational control which includes regular/routine surveys, inspection and
maintenance of the diesel fuel tank, chemical tanks and their ancillary facilities
(pumps, valves and pipes) will be integrated into the plants environmental
management practices so as to identify and rectify any significant product losses
or ongoing spills/leakages which may be occurring;

Areas where regular or periodic handling and dispensing of liquid chemicals are
undertaken, such as maintenance workshop and hazardous waste storage areas,
should be concrete-paved with appropriate secondary containment (drip trays and
bunded areas) provided.

Any accidental spills will be assessed on a case by case basis and remedied,
including excavation and disposal of any contaminated soil (classified as
scheduled wastes) at a secure disposal facility.
Procedures and work instructions on proper chemical handling should be
effectively communicated to all operations and maintenance personnel;

Hazardous materials and waste storage, handling and disposal procedures will be
developed; and

Corrosion protection for steel tanks and their ancillary facilities (pumps, valves
and pipes) will be provided to prevent leaks.

Mitigating measures associated with the management of scheduled wastes and the
residue streams within the RSFs have been discussed in Section 5.5 below.

In addition, groundwater should be monitored on a regular basis during the lifetime of
the plant operation. The groundwater monitoring wells should be located and installed
at upgradient and downgradient locations of the site, as well as at strategic locations
around the site (such as in the vicinity of potential areas of concern) that will allow
the detection of suspected release of contaminants.

If contaminants are present at concentrations above the groundwater quality screening
levels such as the Dutch Intervention Values (DIVs), further assessments will be
necessary to determine the nature and extent of the contamination, as well as to
remove the potential source(s) of contamination. A Human Health Risk Assessment
(and/or an Ecological Risk Assessment, where appropriate) may be required to
determine if the concentrations detected in the impacted media pose an unacceptable
risk to human health and the environment.

5-36

5.4 ENVIRONMENTAL NOISE


There are presently no regulations on limits for noise levels for construction activities
and industrial noise under the Environmental Quality Act, 1974. However, DOE has
published the following guidelines for the management and control of noise:

Guidelines of the Siting and Zoning of Industries (1976): These guidelines were
developed with the objective to assist Federal, State and Local Governments,
planners and industrial/residential developers etc. in determining suitable sites and
adequate buffer zones when locating new industries/industrial areas or residential
areas. These guidelines are also aimed to ensure systematic planning to reduce to
the maximum possible, impact of residual pollutants to nearby residents.

Planning Guidelines for Environmental Noise Limits and Control (2004): The
purposes of these guidelines are (a) for planning purposes, typically by project
proponents, local authorities and consultants (b) to be used in noise impact
assessments, and pre and post EIA compliance verification (c) in quantifying a
noise disturbance on a quantitative manner; and (d) to offer an introductory
explanation in environmental noise control. The document specifies noise limits for
the protection of the public from excessive noise, procedures on environmental
noise measurements and impact assessment, noise parameters for the assessment of
different noise sources; and noise abatement through planning and control.

The Guidelines for Noise Labelling and Emission Limits of Outdoor Sources
(2004): The guidelines were developed to present a uniform method in the
measurement and labeling of outdoor noise sources and to prescribe recommended
maximum permissible sound emission levels for a variety of outdoor noise sources
for the protection of the public from excessive noise.

The document also presents guidance for specifying noise emission levels and noise
labeling requirements, procedures for measurement and labeling of noise emission
of outdoor noise sources; and noise parameters for the description of noise emission
of outdoor noise sources.

The Planning Guidelines for Vibration Limits and Control in the Environment
(2004): These guidelines are to be used for planning purposes, in vibration impact
assessment, pre and post EIA compliance verification, in quantifying a vibration
disturbance on a quantitative manner; and to provide an introductory explanation in
environmental vibration control.

For the management of construction and operational noise, the relevant criteria are
stipulated in Schedule 6 and Schedule 1 respectively of The Planning Guidelines for
Environmental Noise Limits and Control document.

5-37

The Schedule 6 criteria which will be used for the management and control of
construction noise are presented in Table 5.3.1.

Table 5.4.1: Schedule 6: Maximum Permissible Sound Levels (Percentile L
n
and
L
max
) of Construction, Maintenance and Demolition Work by Receiving Land
Use

Receiving
Land Use
Category
Noise
Parameter
Day Time
7.00a.m. 7.00
p.m.
Evening
7.00p.m.
10.00p.m.
Night Time
10.00p.m. 7.00
a.m.
Residential
(Note 2**)
L
90
60 dBA 55dBA * (Note 1)
L
10
75 dBA 70 dBA *
L
max
90 dBA 85 dBA *
Commercial
(Note 2**)
L
90
65 dBA 60 dBA NA

L
10
75 dBA 70 dBA NA
Industrial L
90
70 dBA NA NA

L
10
80 dBA NA
NA
Notes
*1. At these times the maximum permissible levels as stipulated in the Schedule 1 for the
respective residential density type shall apply. This may mean that no noise construction work can take
place during these hours.

**2. A reduction of these levels in the vicinity of certain institutions such as schools, hospitals
mosque and noise sensitive premises (apartments, residential dwellings, hotel) may be exercised by the
local authority or Department of Environment.

Where the affected premises are noise sensitive, the limits of the Schedule 1 shall apply.

3. In the event that the existing ambient sound level (L
90
) without construction, maintenance and
demolition works is higher than the L
90
limit of the above Schedule, the higher measured ambient L
90

sound level shall prevail. In this case, the maximum permissible L
10
sound level shall not exceed the
Ambient L
90
level + 10 dBA, or the above Schedule L
10
whichever is the higher.

4. NA = Not Applicable


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In the operational phase of the project, Schedule 1 which recommends the maximum
permissible sound levels of construction, maintenance and demolition activities as
measured at the property boundary of various receiving landuses (Table 5.3.2) will be
applicable.

Table 5.4.2: Schedule 1: Maximum Permissible Sound Level by Receiving Land
Use for Planning and New Development

Receiving Land Use Category
Day Time
7.00 am - 10.00 pm
L
Aeq

Night Time
10.00 pm - 7.00 am
L
Aeq

Noise Sensitive Areas, Low Density Residential,
Institutional (School, Hospital), Worship Areas.
50 dB 40 dB
Suburban Residential (Medium Density) Areas,
Public Spaces, Parks, Recreational Areas.
55 dB 45 dB
Urban Residential (High Density) Areas, Designated
Mixed Development Areas (Residential -
Commercial).
60 dB 50 dB
Commercial Business Zones. 65 dB 55 dB
Designated Industrial Zones 70 dB 60 dB

Under normal circumstances, the above sound levels apply to outdoor locations at the
real property boundary of the receiver (typically residential areas, or other noise
sensitive area). However, for industrial noise sources in an industrial zone, the sound
level shall be at the property boundary of the industrial site or plant under assessment.

For new industrial developments in areas of existing high environmental noise
climate, the maximum permissible sound level at the receiver locations should not be
higher than noise limits prescribed in Schedule 2 of the Guideline. This schedule
presents an absolute limit for the noise level L
Aeq
based on the existing ambient
percentile index L
A90
plus an allowable noise increment. For industrial land uses the
allowable noise increment is 10 dB.

A perimeter noise survey was undertaken between the 29 and 31 October 2007. The
results showed that the existing night-time L
A90
noise levels were all below 50 dB.
Therefore the criterion for noise levels at the property boundary is L
Aeq
60 dB during
the night-time period.


5-39



Major noise sources during the construction phase of the project include:


Building construction activities including piling; and

Transportation of construction equipment and materials: Vehicular noise will be
generated from the ingress/egress of trucks carrying materials to/from the site.


The nearest noise sensitive receivers are the residential properties located at Kampung
Sg. Ular (3 km northeast of the site), Kg. Gebeng (2.5 km east of the site) and Tanah
Kemajuan Gebeng (2.5 km southwest). The noise impacts arising from the plant will
not impact the noise environment at these receivers.

During the construction phase, activities will be carried out at the site up to 24 hours
per day for 7 days in a week. This will increase the prevailing noise levels at the
boundary of the project site.

The quantification of construction noise requires detailed information on the types,
models, numbers and sound power levels of all construction vehicles, machinery and
equipment and the detailed construction works programme. This information was not
available at the time of reporting and thus the impacts arising from construction noise
are assessed qualitatively. Predictions of noise levels are made for three high-noise
level construction activities.

a. Site Preparatory Works & Piling

Construction vehicles such as bulldozers, tractors, trucks and graders will be used for
site clearing and earthworks. Table 5.4.3 shows the typical noise levels arising from
these vehicles. The cumulative impact of the operation of these vehicles is predicted
to increase the existing noise levels to between 58.2 dBA 75.2 dBA at areas within a
100 m radius of the work site. The maximum noise level of 75.2 dBA represents the
worst case scenario in which all the specified equipment are working together within
the same area with no shielding between the source and the receptor.

5-40

Piling activities typically create a sequence of high intensity noise pulses. Typical
noise levels from some of the common types of piling equipment (without shielding)
are presented in Table 5.4.4. The predicted noise level a 100 m distance from the
piling rig is expected to be in the range of 73.3 100.3 dBA depending on the type of
equipment employed. The use of quieter piling methods such as the bored piles will
further reduce the noise experienced.

Table 5.4.3: Noise Levels for Typical Equipment Used for Construction

Faade
Sound Pressure Level
50m 100m 1000m 2500m
Equipment
Involved
Sound Power
Level (dBA)
Sound Pressure Level (dBA)
Bulldozer 112 70.2 64.2 44.2 36.3
Truck 120 78.2 72.2 52.2 44.3
Lorry 106 64.2 58.2 38.2 30.3
Compactor 120 78.2 72.2 52.2 44.3
Cumulative noise levels from the
above vehicles (a single unit
each).
64.2-81.2 58.2-75.2 38.2-55.2 30.3-47.3

Table 5.4.4: Noise Levels for Typical Equipment used during Piling Activities

Facade
Sound Pressure Level
10m 20m 50m 100m

Equipment
Involved
Sound
Power
Level
(dBA)
Sound Pressure Level (dBA)
Diesel Hammer (Sheet Piles) 147 119.1 112.8 106.2 100.3
Drop Hammer (Precast Concrete
Piles)
128 100.1 93.8 87.2 81.3
Vibratory System (Sheet Piles) 120 92.1 82.8 79.2 73.3

As the predicted noise levels are not significantly higher than the levels presently
experienced at the boundary of the residential property, the noise impacts are short
term, occurring during the construction phase and not adversely significant. With the
implementation of sound construction management practices and implementation of
the recommended mitigation measures, noise impacts are not expected to be a
nuisance during the construction phase.

5-41

b. Transportation of Construction Materials and Equipment

The transportation of construction materials and equipment to the plant site will
increase noise in the vicinity of the site. Presently, the site can be accessed from the
main Gebeng Bypass, the Kuantan-Kemaman Road (Federal Route 3) and East Coast
Highway. These ingress/egress points will be utilised during the construction phase
for the transport of construction materials, equipment and earthmoving machinery.
The duration and magnitude of traffic movements are likely to vary with the stage of
construction resulting in noise fluctuations over time. As the ingress points from these
roads into the GIE are away from residential areas, the noise impacts from the
movement of construction machinery are predicted to be short term, localised and not
significant.

Overall, the noise impacts during the construction phase are predicted to be short-
term, transient and localised to the site and its immediate surrounding (within the
buffer zone of the industrial area).


The following standard noise control practices and measures will be implemented
during the construction phase:

Machinery and construction vehicles that may be in intermittent use will be shut
down between work periods or will be throttled down to a minimum;

The impact of piling noise can be minimised by the selection of quieter pile
drivers such as hydraulic pile, or bored piles.

Material stockpiles and other structures will be effectively utilised, where
practicable, to act as a screen for noisy equipment operating within the
construction works area.

Noisy equipment, such as generators, will be checked for proper installation of
engine silencers to reduce emitted noise. Other machinery with high noise level
should be operated within enclosures.

All transport vehicles must comply with the noise requirements made under the
Environmental Quality (Motor Vehicle Noise) Regulations 1987. The maximum
sound level permitted for trucks used in the transport of goods or materials should
not exceed 88 dBA. Moreover, transportation vehicles should not be overloaded to
avoid driving with full engine capacity which results in higher noise being
emitted.

5-42

In terms of workers safety and health, workers spending long hours on site,
operating machinery and equipment that generate loud noise, will be provided
with protective ear mufflers to prevent hearing impairment/loss.


5.4.3.1 Potential Sources of Impact

Noise is recognised as a form of pollution because it is a public health hazard capable
of causing hearing impairments and psychological stress. Prolonged exposure to high
noise level can cause permanent hearing impairment. This type of impairment may be
incurable although the degradation process is usually gradual. Besides, noise can
cause other negative effects such as loss of concentration and speech interference
effects.

In this section, noise generated from the Advanced Materials Plant during the
operational phase is assessed from an environmental pollution perspective. Matters
pertaining to occupational noise exposure falls within the jurisdiction of the
Department of Occupational, Safety and Health and thus not within the scope of this
EIA report.

There are a number of significant noise sources throughout the plant site including
pumps, motors, process equipment, fans and compressors. For purposes of this study,
only the significant noise sources were identified from the equipment list provided
provide by the Project Proponent.


The future noise levels at the plant site boundaries were quantitatively predicted with
the use of a well established computer modelling programme SoundPlan 6.2
(developed by Braunstein + Berndt, GmbH and accepted for use by the regulatory
authorities in Australia). The data required for input into the model include:

Meteorological information;
Topographical data;
Ground absorption;
Building transmission loss; and
Noise source sound power levels.

The objective of the noise assessment is to quantitatively predict:

The highest noise level at the boundary of the plant site; and
Noise levels when propagated over a 5 km radius of the site.

5-43

a. Methodology

For operational and truck noise impacts, the computer model utilised the CONCAWE
algorithms. The CONCAWE methodology was developed from a research paper,
published in 1981, under the title, The propagation of noise from petroleum and
petrochemical complexes to neighbouring communities. It has been used as it
explicitly deals with the influence of wind and the stability of the atmosphere.

b. Modelling Scenarios and Assumptions

A single scenario was modelled which represents the combined noise levels from the
operation of the plant and the movement of trucks transporting raw material
(lanthanide concentrate), reagents and finished products.

The predictions are based on two assumptions:

Worst-case environmental conditions when the prevailing wind blows 100% of
the time in the direction of the receiver, i.e. in a north-easterly-easterly direction.

All equipment and machinery within the plant are operating simultaneously.

Truck movements consisting of 68 trucks per day for the reagents and 18 trucks
per day for the concentrate;
Trucks operating 24 hours per day; and
Speed on site is 30 km/h.
As the plant is to operate continuously, the night-time (10.00 pm - 7.00 am) noise
level criteria is the most critical and as such, the results are calculated as L
Aeq (9 hour)

dB levels.

c. Meteorological Data

The meteorological data used in the assessment is based on a 20-year period data
obtained from the Sultan Abdul Aziz Shah Airport in Kuantan, Pahang. (described in
detail in Chapter Four of this document).

d. Topography

As the subject site and surrounding land is relatively flat, it has been assumed that the
there are no significant hills in the area that can attenuate the sound propagation. This
is considered to be a conservative approach to the noise prediction.

5-44

e. Ground absorption

Ground absorption varies from a value of 0 to 1, with 0 being for an acoustically
reflective ground (e.g. water or bitumen) and 1 for acoustically absorbent ground (e.g.
grass). In this instance, as this project is predominately located around industrial area,
the ground absorption has been set to a value of 0.5 (50% hard ground).

f. Building Transmission Loss

When noise sources are located within a building, the transmission loss of the
building material is required in order to calculate the noise reduction from inside to
outside. Table 5.4.5 shows the transmission loss values in octave bands assumed in
the noise modelling.

Table 5.4.5: Transmission Loss Values Used in Modelling, dBA
Octave Band Centre Frequency (Hz) Wall Construction
63 125 250 500 1k 2k 4k
Sheet Metal 14 18 22 27 32 37 42
Inner Leaf Brickwork,
Outer Leaf Sheet
Metal
32 34 34 43 58 73 83

g. Sound Power Data

Source sound power level data for the proposed plant have been obtained from file
data of similar plant measured by Lloyd George Acoustics. The sound power levels
are provided in Table 5.4.6.

5-45

Table 5.4.6: Source Sound Power Levels, dB
One-Third-Octave Band Centre Frequency (Hz)
Source/Quantity 25
31.5
40
50
63
80
100
125
160
200
250
315
400
500
630
800
1k
1.25k
1.6k
2k
2.5k
3.15k
4k
5k
Overall,
dB(A)
per Unit
88 82 80 75 72 68 65 59
86 80 78 72 70 66 64 56
Conveyors
(Covered)
85 78 76 72 69 65 61 54
77/m
111 105 104 104 101 97 95 94
110 102 105 105 101 99 94 92 Compressor House
108 105 108 103 98 95 94 92
108
Cooling Tower 95 110 110 108 105 101 98 95 107
Rotary Kiln 110 101 101 100 102 101 94 84 105
Rotary Kiln Blower 93 99 104 100 104 97 95 92 104
Conveyor Drives 93 95 97 99 99 99 101 94 105
Blowers/Exhaust
Fans 90 99 104 100 104 97 95 92
104
100 90 94 92 91 97 95 89
90 97 98 93 95 98 95 85 Pumps
91 100 90 89 97 99 90 83
106
Front-end Loader
CAT 966 or Volvo
L330C
105 114 110 105 106 102 99 95 108
Truck Moving at
30km/h
94 97 99 107 99 96 95 91 103
Note 1: The sound power level for the conveyor is for standard idlers at reasonably high speed.

As manufacturers data for the plant proposed for the project was not available at the
time of preparing this assessment, the following noise levels, when measured at one
metre from the plant, should be specified:

Rotary Kiln 97 dB(A)
Cooling Tower 99 dB(A)
Kiln Blower 97 dB(A)
Covered Conveyor 70 dB(A)
Conveyor Drive 97 dB(A)
Exhaust Fans 96 dB(A)

5-46

Compressor House 85 dB(A)
Pumps 98 dB(A)
Front-end Loaders 100 dB(A) (or 86 dB(A) at 5 metres)

h. Results and Discussion

The results of the noise assessment are presented in Exhibits 5.4.1 and 5.4.2, as noise
level contours overlaid on a map of the surrounding area. As the plant is to operate
continuously, the night-time (10.00 pm - 7.00 am) noise level criteria are the most
critical and as such, the results are calculated as L
Aeq (9 hour)
dB levels.

From the results presented in Exhibits 5.4.1 and 5.4.2, the highest predicted noise
level from the operation is received on the northern boundary of the proposed site.
This level, which includes truck noise, is L
Aeq (9 hour)
62 dB. The predicted noise level
is dominated by the front-end loaders moving between the Tertiary Leaching Plant
and the Residue Storage Facilities.

Kemajuan Gebeng (2.5 km southwest). The predicted noise levels are these locations
are calculated to be below L
Aeq
35 dB and therefore not considered to be of
significance.

When compared to the Department of Environment Malaysias The Planning
Guidelines for Environmental Noise Limits and Control, it can bee seen that the night-
time level at the northern boundary marginally (2 dB) exceeds the night-time criterion
of L
Aeq (9 hour)
60 dB. However, these predictions assume that all four front-end loaders
will be operating continually and simultaneously for the entire night-time period,
which may not be the case in reality. Should the operation be intermittent, the
L
Aeq (9 hour)
level would be lower and may then comply.

It is therefore recommended that once the plant is operational, a noise survey be
undertaken on the boundary of the site. Should it be found that the front-end loaders
or other plant is causing the noise levels to exceed the criterion, noise control can be
undertaken to ensure compliance. For the front-end loaders, suitable noise control can
include upgrading the engine covers and exhaust system.

The impact from trucks on public roads is considered to be minimal considering the
low truck volumes (86 trucks per day) and the existing traffic volumes. Also, as the
trucks are likely to be taking different routes to the site, unlike the scenario of
trucking campaigns from a port to a particular site, there is not a concentration of
noise at specific locations.

Assuming the plant specifications and expected truck movements used in the model,
the results clearly indicate that during both normal operation and with the additional

5-47

noise associated with transportation of the lanthanide concentrate from the port, the
operation of the plant complies with the Department of Environment Malaysias The
Planning Guidelines for Environmental Noise Limits and Control at all times.


Assuming the plant specifications and expected truck movements as detailed in
Section 5.4.3.2, the predicted noise levels from the proposed Advanced Materials
Plant are expected to marginally exceed the perimeter noise criteria prescribed in the
Department of Environment Malaysias The Planning Guidelines for Environmental
Noise Limits and Control along the plants northern boundary. However these
predictions are conservative in their approach and it is recommended that once the
plant is operational, a survey is undertaken on the boundary of the site and noise
control is undertaken if the criteria is exceeded.

However, to further reduce the plant operating noise and as best industrial practice,
the following measures will be implemented:

When selecting the equipment models for the plant from the various vendors, the
noise attenuation features of the equipment will be given due consideration. In
general, the newer equipment models tend to have more effective noise
attenuation features. Where practical and cost effective, these equipment should
be given priority. It is recommended that performance guarantee or contract
specifications stipulate a requirement limiting the noise level of the equipment to a
maximum of 85 dB(A) at 1m where practical.

For additional noise attenuation, engineering measures such as installing mufflers,
enclosures, barriers, lagging, noise-absorptive materials and silencers may be
employed where practical.

Where practical and feasible, noisy equipment should be housed within a building
or an enclosure. The enclosures may range from a complete fully accessible room
with proper air ventilation system to a structure which has side claddings that act
as noise barrier.

Insulation of equipment piping accord further noise reduction.

The orientation of the equipment within the plant area will be such, so as to
capitalise on the existing buildings and structures as noise barriers. Barrier
shielding in many instances has been observed to significantly attenuate noise
levels. For example, an intervening building between source and receiver may
reduce the noise level by about 5 dBA.

5-48

The layout of noisy equipment within the plant will be aligned in a manner such
that the distance of the equipment from the boundary is maximized, at least 25
metres from the nearest neighbouring site boundary.

Noise emitted by the compressors, fans and pumps can be further controlled by
reducing the vibration level of the machinery and their ancillaries.

For the control of occupational noise, workers operating within noisy areas of the
plant will be provided with ear plugs or ear muffs. In high noise level environments
within the plant, it is advisable to wear both types in combination. The noise
attenuation or protection afforded by ear protectors varies with the frequency of the
noise, providing more protection at higher frequencies. At average frequencies of 500
Hz to 1000 Hz, ear plugs alone provide protection of about 22 dB (A). Ear muffs are
better, providing attenuation of 30 dB(A) and in combination, the protection accorded
is in the range of 34 dB(A).

5.5 SOLID WASTE


General industrial, commercial and domestic wastes are controlled under the Local
Government Act 1976 and Refuse Collection, Removal and Disposal By-Laws
stipulated under the Act. This Act enables State Authorities to prohibit the deposition
of wastes in streams, watercourses and public drains. The by-laws specify that
commercial and industrial wastes may be collected and disposed of on a fee basis as
prescribed by Local Authorities. Contravention of the by-laws is an offence. In
addition, the Solid Waste and Public Cleansing Management Act, 2007 was recently
gazetted and will come into operation in the near future.

The Environmental Quality (Scheduled Wastes) Regulations, 2005, under the
Environmental Quality Act, 1974, regulates the responsibilities and procedures related
to storage, handling, transport and disposal of scheduled or hazardous wastes. Under
the First Schedule of the regulations, hazardous wastes have been grouped under 5
broad groups: Metal and Metal Bearing Wastes (SW1); Wastes containing principally
inorganic constituents which may contain metals and organic materials (SW2);
Wastes containing principally organic constituents which may contain metals and
inorganic materials (SW3); Wastes which may contain either inorganic or organic
constituents (SW4); and Other wastes (SW5). Under the five groups 77 types of
wastes have been classified as scheduled waste with designated codes.

5-49

Under these Regulations, waste generators are required to keep an up-to-date
inventory of scheduled waste generated, treated and disposed off. The regulation also
requires proper labelling of containers and storage areas as well as prohibition of
storage of incompatible waste. In the case of transporting the waste from the waste
generator to the treatment and disposal facilities, the transport of waste shall conform
to the specified consignment note system and only carried out by DOE-licenced
transporters. Scheduled wastes may only be transported to scheduled waste treatment
and disposal facilities which have a valid licence to occupy or use the premises from
the DOE.



The types of solid wastes generated during the construction phase can be broadly
categorised based on their nature and ultimate disposal method into the following:

Municipal waste;
Scheduled waste (regulated hazardous wastes); and
Unregulated wastes.

Improper disposal of these wastes at unauthorised areas will contribute to unhealthy
and unattractive surroundings. Poor management of construction waste will result in
the creation of illegal dumping grounds in secluded areas at the nearby villages and
surrounding forested areas. These illegal dumps provide an ideal habitat for disease-
vectors such as mosquitoes, flies and rats which potentially cause health impacts to
nearby settlements. In addition improper disposal of hazardous waste will result in
contamination of the soil and potentially groundwater. They also pose fire hazards
during the dry seasons, clog the local drainage system and caused localised ponding
and even flooding of nearby streams and river systems during the monsoon season.
The dumps are also sources of adverse negative odour impacts.


a. Municipal Wastes & Scheduled Wastes

Waste material under this category would include the following:

Construction spoil originating from the construction works. These include inert
and non-toxic materials such as crushed stones and gravel, rejected wood based
material, bricks, concrete slabs, steel frames, PVC pipes, cement/grouting mixes,
etc.

5-50

General waste which includes non-inert and non-toxic waste such as plastics,
packaging, paper, glass, metals, planks, putrescible food and other wastes
generated from daily activities of the site.

Vehicle/equipment parts such as tyres, metal components, etc.

In the event foreign workers are employed for the construction phase, there would
be a need to provide temporary accommodation facilities. These facilities will
give rise to the generation of solid waste and sewage. As the industrial area is not
remotely located with easy access to the towns of Balok and Gebeng,
accommodation may be provided at existing residential areas. However, in the
event construction activities extend beyond the normal working hours and for
convenience these temporary housing facilities may be erected onsite).

Domestic waste generated from the site offices and workers camp include plastic
wrappings or other packaging material, paper, glass and putrescible waste
material from the kitchen.

Schedule wastes generated on site include the following:

Spent filter cartridges, scrap batteries, mineral oils/engine cleaning fluids;

Residues and waste of industrial paints, pigments, lacquers, curing compounds,
etc;

Various types spent/waste oil and soil/rags contaminated with oily residues from
construction equipment, vehicles and diesel generators; and

Spent solvents.

The potential impacts arising from improper management of both these waste
categories include the following:

Odour nuisance from decaying organic and food wastes from municipal wastes;

Improper disposal of putrescible municipal wastes on-site would attract disease
carrying rodents and insects. This may subsequently result in public health
impacts (such as dengue) within the nearby villages.

Improperly managed wastes will be washed into the temporary drainage channels
during rainfall events potentially obstructing the drainage flow. If unattended, this
will result in stagnant water in the drains.

Contamination of soil and groundwater resources as the shallow groundwater
table within the project site is at 1.03.5 m bgls;

5-51

Aesthetic issues due to poor management of the wastes;

The wastes are also potential fire hazards within the site. Any fires occurring
within the site, if uncontrolled can spread to the surrounding areas.

c. Unregulated Wastes

The unregulated wastes generated by the project would include the following:

Excavated topsoil;
Excavated unsuitable soil; and
Vegetative biomass.

During the construction phase, topsoil and unsuitable foundation material will be
removed at the construction works area.

As the site has been largely cleared (approximately 98% cleared with very little sparse
vegetation and shrubs) the quantity of waste vegetative biomass generated is therefore
very small. Options such as mulching and composting within the site, where practical
should be considered, if necessary.


Burning of vegetative biomass residues and construction wastes within the site is
strictly prohibited as apart from polluting the atmosphere and contributing to the
occurrences of haze events, the activity poses a risk of fire spreading to the adjoining
green areas. In addition open burning of activities other than the declared activities
identified in the Environmental Quality (Declared Activities) (Open Burning) Order,
2003 is illegal. The declared activities are mainly activities related agriculture and
animal husbandry.

a. Municipal Waste

The potential environmental impacts arising from the improper management of
municipal wastes can be minimised with the implementation of the following
practices:

Good housekeeping practices are essential within the site and especially critical at
the workers camp (if set-up within the site premises).

General construction spoil should be recycled on site as much as possible. For
example, construction aggregate materials, cement and rock are readily used on
site where possible as backfill material for low lying areas.

5-52

Domestic waste generated from the workers camps should be stored in garbage
bins/secure containers and be collected regularly by a licensed contractor for
disposal at an approved landfill.

Unsalvageable construction spoil should be stockpiled at a designated site and
sold to salvage yard operators or other contractors interested in recycling the
material. Alternatively, disposal arrangements can be made with registered private
contractors or Majlis Perbandaran Kuantanto carry out regular collection and off
site disposal at the approved disposal site.

b. Scheduled Wastes

Types of scheduled wastes potentially generated during the construction phase will
require proper handling, storage and disposal in compliance to the scheduled waste
regulations. The copies of the waste consignment notes will be filed by the Contractor
for record.

The construction works Contractor shall ensure that only licensed scheduled waste
contractors are employed for the transportation of these scheduled wastes to the
scheduled waste disposal facility, the Integrated Scheduled Waste Management
Centre (ISWMC) at Bukit Nanas, Negeri Sembilan.

To prevent potential soil and groundwater, the mitigation measures recommended in
Section 5.5.2.3 shall be applicable.

c. Unregulated Waste

Topsoil refers to soil layers that can be used as a revegetation medium during
rehabilitation or landscaping of the site. Topsoils have chemical, physical and
biological attributes that assist in the rapid re-establishment of plants as these soils
contain a natural stock of seeds and beneficial micro-organisms. Due to their higher
organic matter, the excavated soil may be stockpiled within the site and then reused
within the green areas proposed at the site.



Solids wastes generated during the operational phase of the Advanced Materials Plant
include:

Residues from the physio-chemical processes within the Cracking & Separation
Plant;

5-53

Scale from neutralisation tanks and clarifiers in the Neutralisation Plant;

Scale from process piping and vessels that handle lanthanide sulphate solution;

Waste refractory from kiln maintenance;

Filter cloths from the FGD, NUF and WLP filtration processes;

Sludge from the Waste Water Treatment Plant (WWTP);

Scheduled wastes; and

General wastes.

With the exception of scheduled wastes and general wastes, all other wastes listed
above are classified as radioactive wastes by the Atomic Energy Licensing Board
(AELB) and thus the storage and management of these wastes must comply with the
applicable regulations under the Atomic Energy Licensing Act, 1984 and, endorsed by
the AELB. Matters pertaining to the on-site storage and management of these wastes
come under the purview of the Board. Lynas has engaged Malaysian Nuclear Agency
(Nuclear Malaysia) as the Radiological Consultants for this project and for the
preparation of a Radiological Impact Assessment (RIA) which evaluates the
radiological impacts of the plant operations to humans and the environment. A copy
of the RIA has been submitted to the AELB for approval as part of the Class A
Milling Licence application requirements. The Class A Milling Licence is required
under the Atomic Energy Licensing Act, 1984 for plants involved in the processing of
radioactive materials.

For purposes of this EIA, only the non-radiological impacts pertaining to the waste
management are identified and assessed as the management of radioactive wastes
comes under the purview of the AELB (refer Appendix 1).

a. Radioactive Wastes

Residues, Refrcatory, Filter Cloths & WWTP Sludge

The three residue streams produced will include:

Water Leach Purification (WLP) residue resulting from the leaching and
purification of the water soluble lanthanide components from the calcined,
cracked concentrate in the Cracking & Separation Plant;

Flue Gas Desulphurisation (FGD) residue from waste gas scrubber system; and

5-54

Neutralization Underflow (NUF) residue from the High Density Sludge system
which is the pre-treatment system of the liquid waste streams arising from the
Cracking & Separation Plant.

All residue streams and the filter cakes will be stored onsite within the engineered
Residue Storage Facility (RSF) until a suitable permanent disposal option is selected
by Lynas in conjunction with the AELB. The location of these RSF units is presented
in Exhibit 2.1 (Chapter Two).

Based on the basic engineering design, an estimated 145,200 tons of residues will be
generated annually. A summary of the three residue streams in terms of annual dry
mass and volume generated, and the state of residue during disposal is presented in
Table 5.5.1.

Table 5.5.1: Residue Streams Summary
Residue Stream Annual Dry
Mass
(Tons/annum)
Assumed
Dry Density
(t/m
3
)
Volume (m
3
) for 10
Year Project
Lifespan

State
2
of
Residue
Water Leach-Purification
(WLP) solids

32,000 0.70 478,800 Paste
Flue Gas Desulphurisation
(FGD) Solids

27,900 1.05 162,600 Paste
Neutralisation Underflow
(NUF) Solids

85,300 1.05 91,600 Paste
Total 145,200 2,766,600
Notes:
1
Dewatered residues with water content between 3040% are referred to as paste.

Typical compositions and radioactivity of the three residue streams and sludge from
the WWTP are shown in Table 5.5.2.

5-55

Table 5.5.2: Major Waste Composition of the Residue Streams and Sludge from
the WWTP

WLP FGD NUF

Sludge *
Composition Weight
%
Weight % Weight
%
Weight %

Iron Oxide 19.74 0.16 0.17 2.4
Phosphorus Oxide 19.77 0.00 0.00 0.3
Aluminium Oxide 2.86 0.12 0.23 0.4
Calcium Oxide 1.36 28.39 22.31 -
Magnesium Oxide 0.03 0.00 7.06 4.2
Manganese Oxide 0.37 0.00 0.37 -
Barium Oxide 0.3 - - 0.01
Sulphite 0.00 0.00 0.03 -
Zinc 0.1 - - -
Strontium Oxide 0.4 - - -

ppm ppm ppm ppm
Fluoride - 1800 - 71
Thorium Oxide 1655 0.00 0.00 26
Uranium Oxide 22.5 - - 1.1
Sodium Oxide - 0.00 0.13 36
Potassium Oxide - 0.00 0.00 28

Bq/g Bq/g Bq/g Bq/g
Radiation
(Specific Activity)
62.0 0.47 0.25 1.1
* Note: Sludge is from Wastewater Treatment Plant

Scales

Calcium sulfate scale from the neutralisation tanks and clarifiers in the HDS
Neutralisation Plant have similar physico-chemical characteristics as the NUF solids
and will be disposed of in the NUF cell of the RSF.

Calcium sulfate scale from process piping and vessels that handle the lanthanide
sulphate solution primarily consists of calcium sulphate and low levels of radium, and
will be disposed of at the WLP solids cell of the RSF.

Waste Kiln Refractory and Filter Cloths

Waste refractory from kiln maintenance (which will be generated at an estimated 5
50 tonnes every two years) and filter cloths from filtration processes (estimated at 5
50 tons per annum) may exhibit low levels of radioactivity and will be disposed of at
the RSF.

5-56

b. Scheduled Wastes

Scheduled wastes generated from site operations are anticipated to include:

Used engine, hydraulic and lubricating oil from maintenance workshop and
general lubricating and maintenance activities;

Used batteries from vehicles and equipment;

Discarded or off-specification chemicals (including acids, alkalis and reagents
used);

Containers, bags or equipment contaminated with chemicals or mineral oil; and

Rags, plastics, papers or filters contaminated with chemicals or oils.

c. General Waste

General/municipal wastes arising from the operation of the plant include canteen
waste, office wastes from the administration offices and miscellaneous wastes from
other working areas which may include, waste paper, plastic, cardboards etc.



Potential environmental impacts associated with on-site residue storage (RSF)
include:

Soil and groundwater contamination; and

Residue embankment slope stability and erosion problems.

As shown in Table 5.6.2 the residues are primarily composed of oxides of iron,
aluminium, silicon, magnesium, calcium and phosphorus. These are compounds that
are readily found as major constituents that make up soil minerals.

The complete environmental impact assessment of these radioactive wastes will be
undertaken as part of the Radiological Impact Assessment by the Malaysian Nuclear
Agency for submission to the Atomic Energy Licensing Board.

The potential leaching of trace metals, including radioactive lanthanide metals, from
the residues may result in contamination of the underlying soil and groundwater
resources.

5-57

It is noted that there are no groundwater abstraction points or direct groundwater users
have been identified on-site or at immediate down-gradient locations. Additionally,
there are no other potentially sensitive groundwater receptors within the zone of
impact.
Residue embankment slope stability and erosion may also result in release of residues
outside of lined cells and pose a potential health and safety problem in addition soil
and groundwater contamination. A preliminary embankment slope stability
assessment has been conducted based on the subsurface profile encountered during
the site investigation and estimated design parameters in order to ensure the factor of
safety (FOS) of slopes against global failure. In accordance with ANCOLD
(Australian National Committee on Large Dams) guidelines the required FOS for
short-term and long-term stability are 1.3 and 1.5, respectively. The preliminary slope
stability assessment indicates that the FOS against global failures for embankment
height up to 8m is acceptable in the long term case but not the short term case. Slope
stability impacts should be appropriately addressed (see Section 5.5.3.3).

b. Scheduled Wastes

The primary concern with regards to scheduled waste management is spillages which
will potentially contaminate surface-runoff, soil and groundwater.

Based on the types of scheduled waste potentially generated from the site, the
quantities will not be significant. These wastes can be sold to scheduled waste
recycling contractors who are licensed by DOE. The impacts arising from the storage
and handling of the scheduled wastes categories identified are not significant.



In ensuring that the potential environmental impacts arising from the on-site storage
of the radioactive residue streams are minimised to a sustainable level, Lynas has
developed a technically sound waste management strategy which is described Section
3.2 Preliminary Comparison of Residue Disposal Options (Refer Appendix 3). It is
recommended that this strategy be incorporated into the Environmental Management
Plan (EMP) prepared for operational phase and endorsed by the AELB and the DOE
for implemention. The waste management strategy developed by Lynas is directed
towards the design of an environmentally sustainable residue storage facility (RSF)
while maximizing the potential for recycling or reuse of each residue stream back into
the process.

5-58

The Project Proponent has commissioned a conceptual engineering design of the RSF,
taking into account key engineering design and environmental considerations. Each
residue stream has different characteristics in terms of water content, its composition
and radioactivity. Design considerations of the RSF as well as residue management
are dependent on these characteristics. One conceptual design scenario has been
presented to the AELB and are currently under evaluation.

The key features of the RSF design which provides for the protection of
environmental resources, namely soil and groundwater are summarised below:

Fill material will be placed at low-lying areas to ensure that the base of the RSF is
at least 1 m above groundwater level. It is recommended that the fill material
comprises soils with low permeability;

All residue storage cells will be lined with 300 mm low permeability compacted
clay liner overlain by a 1 mm thick HDPE liner to prevent seepage into the
underlying soil and groundwater;

All supernatant liquors and rainfall runoff from FGD and NUF residue cells will
be collected and pumped via pipeline to a HDPE-lined FGD/NUF surface water
retention pond with capacity for the 1 in 100 year storm event based on climatic
data for the region. Water from this pond will be directed to the Waste Water
Treatment Plant (WWTP). The treated waste water will then be discharged off-
site into an external earth drain which discharges into Sungai Balok. All off-site
discharges will be monitored to comply with the limits stipulated in Standard B of
the Environmental Quality (Sewage and Industrial Effluent) Regulations, 1979;

Supernatant liquors and rainfall runoff from the WLP residue cell will be pumped
to a separate HDPE lined surface water retention pond (with capacity for the 1 in
100 year storm event based on climatic data for the region) and subsequently
recycled into the cracking and separation process stream. No off-site discharge is
anticipated;

During heavy rainfall and in particular the monsoonal wet season the surface of
the residue is expected to become wet, soft and slippery making placement of
residue during this period problematic due to the poor trafficability of the residue
surface. Therefore, a temporary cover may be required to keep the area of active
residue placement dry during the wet season. A potential solution to this problem
is to size the drying shed with sufficient capacity so residue can be stockpiled
during the wet season awaiting placement in the RSF during drier weather;

5-59

To ensure a long term slope stability, perimeter RSF embankment walls will be
designed and built with a gentle gradient of 3H:1V. In addition, the maximum
height of embankment will be limited to 8 m above existing ground level. The
preliminary slope stability assessment indicates that the proposed embankment fill
height of 8m results in a FOS of less than the acceptable minimum of 1.3 under
short-term undrained conditions. This can be overcome by the placement of an
additional 1.0m of well compacted select fill across the RSF area. Further
assessment of the consolidation behaviour of the subsurface soils is required to
confirm the short-term stability of the embankments; and

Erosion protection in the form of rip-rap or geotextiles will be incorporated.

A conceptual cross-sectional design of the RSF showing liner and embankment
details are provided in Exhibits 5.5.1 5.5.4.

In addition to constructing the RSF which incorporates environmental protection
features, the Project Proponent is also exploring the potential beneficial uses of each
of the three residue streams. The reuse of residues will significantly reduce the
quantity of residue for on-site storage and the allocated footprint for the RSF within
the site. Details of these reuse options are presented in the Preliminary Comparison
of Residue Disposal Options presented in Appendix 3.

A summary of these end uses are presented in Table 5.5.3 below.

Table 5.5.3: Summary of Potential Residue End Uses

Residue Stream Potential Residue End Uses
Water Leach-Purification (WLP)
residue

Fertilizer (high levels of phosphorus and magnesium)
Raw material for Cement manufacture

Flue Gas Desulphurisation
(FGD) residue

Plasterboard market (calcium sulphate)
Raw material for cement manufacture
Neutralisation Underflow (NUF)
residue

Fertilizer (high levels of magnesium, aluminium and
calcium sulphate)
Raw material for cement manufacture

In addition, the design, construction and operation of the RSF must be monitored and
carried out so that it does not result in adverse impacts identified in the previous
section. Prevention and control measures include the following:

RSF surface water retention ponds should be sized to accommodate monsoon and
storm events over the life of the project;

5-60

A detailed settlement and slope stability including seismic sensitivity analyses to
ensure the stability of the landform created should be considered;

During the construction of the RSF, QA/QC procedures should be implemented to
ensure that the liner system of the RSF is installed without any compromise to its
integrity. This includes on-site full time supervision of a qualified engineer
during liner installation and strict quality inspection checks;

Frequent inspection and maintenance of the surface runoff and leachate collection
and treatment systems must be carried out to ensure continuous operation,
particularly during the wet season;

Monitoring of groundwater quality in the vicinity of the RSF should be conducted
on a regular basis. More groundwater monitoring wells should be installed at
strategic locations to detect potential groundwater contamination;

Access to the RSF should be restricted to authorized personnel only and
appropriate personal protective equipment (PPE) must be worn to reduce the risk
of potential exposure to low level radiation and other contaminants from the
residues; and

A RSF Management Plan which covers aspects of residue deposition, rainfall
runoff management, dust generation and entrainment, environmental monitoring,
health and safety as well as site closure and rehabilitation should be developed
and implemented as part of the EMP prepared for the operational phase of the
plant.

As part of the fill/construct methodology for the RSF, cells will be capped once
design capacity is achieved creating a landform with positive drainage. Capping is
envisaged to comprise a 500mm thick rock-fill layer to serve as a capillary break,
overlain by low permeability clayey soil and topsoil to lower the risk of infiltration.
Interaction between rainfall and surface water runoff from capped cells and
permanently stored residues will be minimised and the final site topography will
encourage surface water to drain off-site to prevent ponding and standing water.

b. Scheduled and General Waste

Scheduled wastes generated from plant operations will require proper handling,
storage and disposal. These practices shall meet the requirements stipulated in the
Environmental Quality (Scheduled Waste) Regulations, 2005.

5-61

Scheduled wastes generated at the site can either be recycled or disposed at approved
facilities. There is currently a market of spent oils, solvents, lead batteries, oil filters
and paints. These can be readily sold to DOE-licensed recyclers. There are a few
facilities licenced to recover spent catalyst, waste oil, spent hydraulic oil and
chemicals that are discarded or off-specification located nearby in the Gebeng
Industrial Area and Teluk Kalong Industrial Area.

Scheduled wastes which cannot be recycled but require disposal will need to be
disposed at the Integrated Scheduled Waste Management Center (ISWMC) operated
by Kualiti Alam which is presently the only licensed facility in Malaysia. Upon
signing a contract with Kualiti Alam, the company will arrange for their marketing
division to coordinate the entire packaging and transportation of the wastes to the
integrated facility.

Specifications for scheduled waste storage (pending off-site removal) have been
stipulated in the Regulations. The wastes shall be stored within a designated storage
area and the design of the storage area shall comply with the requirements of the
Regulations.

Salient features of the design include:

Provision of hardstanding, with impervious flooring (such as concrete);

A bund wall capable of containing 110% of the contents of the largest storage
tank volume in the event of spill;

The discharge outlet of the bunded area must be appropriately designed (e.g. with
valve) so that there is no direct discharge or release of material away from the
storage area;

Preferably constructed with walls and roof to protect against the weather (sun and
rainwater ingress);

Well-ventilated and well-lit;

Incompatible scheduled wastes must be stored in separate containers and placed
in separate secondary containment areas; and

Locked when access is not required and should be accessible only to authorized
persons.

Other key requirements of the regulations are as follows:

DOE shall be notified on the generation of the scheduled waste within the facility;

5-62

Up to date inventories of the scheduled waste generated, treated and disposed of
are to be maintained for inspection by DOE;

All storage bins/areas should be properly labelled and identified. Storage of
incompatible wastes is prohibited;

The off-site transport of scheduled wastes from the point of generation to the final
disposal facility must utilise the Consignment Note System; and

The waste generator is responsible for informing the (DOE-licensed) waste
transport contractor on the nature of the waste and of the precise actions necessary
to preserve human life and the environment in the event of an accident during the
transport.

5.6 AMBIENT AIR


Industrial gaseous emissions are regulated by the Environmental Quality (Clean Air)
Regulations 1978. Under these Regulations, industrial facilities are required to comply
with three types of standards: A, B and C under the Stack Gas Emission Standards
specified under sub-regulation 27.

All new operations are required to comply with Standard C, while Standards A and B
are applicable for operations which commenced prior to the promulgation of this
regulation in 1978. These standards are regarded as acceptable conditions for air
emissions in Malaysia. The standards are given based on the sources of emission for
certain activity or from any other sources, which is normally applicable for most
manufacturing industries. No standards have been listed specifically for general
manufacturing operations although standards exist for sulphuric acid mist/sulphur
trioxide, solid particles, metal and metallic compounds, chlorine gas, hydrogen chloride,
fluorine, hydrofluoric acid, inorganic fluorine compound, hydrogen sulphide and oxides
of nitrogen from any source. The limits prescribed are presented in Table 5.6.1.

Any erection, installation, re-siting or alteration of fuel burning equipment or of a
chimney, from or through which air impurities may be emitted or discharged, will
require a Written Approval from the DOE Pahang State office. This includes the
installation of boilers and emergency/back-up generators that are rated to consume
any liquid or gaseous matter at or more than 15 kg or more per hour. The application
for the Written Approval can be made to the DOE State office using Form AP/E/1/98.
Information to be provided in the application form include design and operational
details of the fuel burning equipment/chimney/pollution control equipment. The
processing duration for the Written Approval is approximately 1 month.

5-63

Currently, there are no established standards for ambient air quality in Malaysia but
DOE has adopted some recommended guideline levels (Recommended Malaysian Air
Quality Guidelines (RMAQG)) for a number of pollutants including ozone (O
3
),
carbon monoxide (CO), nitrogen oxide (NO
2
2
), particulates
(Total Suspended Particulates (TSP)) and respirable dust (PM
10
), lead and dustfall.
The RMAQG was prepared by the DOE in 1989 based on the Australian and New
Zealand national standards for the protection of public health. The levels will apply for
ambient air quality monitoring. The criteria stipulated in the RMAQG are presented in
Table 5.6.2. The corresponding limits recommended by the World Health
Organization (WHO, 2005) are also presented in the table.

The Environmental Quality Act, 1974 prohibits the burning of any combustible
material or refuse unless a license is granted by the Director General of the
Environment. This would include a variety of waste materials (e.g. palm oil, rubber
trees & other vegetation and waste generated by construction) during both the
construction and operational phase of the project.

Under the Environmental Quality (Declared Activities) (Open Burning) Order 2003,
open burning is strictly prohibited within industrial premises unless it is a declared
activity. The Order specifies 15 declared activities which is generally related to
research, religious rites/worshipping, small scale social activities, permitted industrial
gas flaring, disease control and agricultural activities.

The Environmental Quality (Dioxin and Furan) Regulations 2004, specifies a not to
exceed concentration limit of 0.1 nanogram/Nm
3
TEQ for air emission of dioxin and
furan for incinerators of schedule waste, municipal waste, pulp & paper industry
sludge and sewage sludge.

5-64

Table 5.6.1: Recommended Malaysia Air Quality Guidelines

Pollutant Averaging Time Malaysian Air Quality
Guidelines
WHO
(2005)
4

ppm g/m
3
g/m
3

Sulphur dioxide
(SO
2
)
1 hr 0.13 350
24 hrs 0.04 105 20

PM
10
24 hrs 150 50
1 year 50 20

TSP 24 hrs 260 -

Nitrogen dioxide
(NO
2
)
1hr 0.17 320 200
24 hrs -
1 year 0.04 90 40

Carbon Monoxide
(CO)
1 hr 30.00 35 mg/ m
3

8 hrs 9.00 10 mg/ m
3

Ozone (O
3
) 1 hr 0.10 200 -
8 hrs 0.06 120 100

Lead (Pb) 3 months 1.5 1.5

Emission of black smoke from diesel powered vehicles and construction equipment
must comply with the emission limits specified under Schedule I of the
Environmental Quality (Control of Emission from Diesel Engines) Regulation 1996.

4
World Health Organisation (WHO) (2000): Guidelines for Air Quality, World Health Organisation.


5-65

Table 5.6.2: Permissible Gaseous Emissions Limits from any Trade, Industry or Process
(Environmental Quality (Clean Air) Regulations, 1978)

Substance Emitted Sources of Emission Standards

(a) Acid Gases Manufacture of sulphuric acid 1. Equivalent of:
Standard A: 7.5
Standard B: 6.0
Standard C: 3.5 gramme of sulphur
trioxide / Nm
3
of effluent gas,
2. Effluent gas free from persistent mist

(b) Sulphuric acid mist or
sulphur trioxide or
both
Any source other than
combustion process and plant
for manufacture of sulphuric
acid as in (a) above.
1. Equivalent of:
Standard A: 0.3
Standard B: 0.25
Standard C: 0.2 gramme of suplhur
trioxide / Nm
3
of effluent gas,
2. Effluent gas free from persistent mist

(c) Chlorine gas Any source Standard A: 0.3
Standard B: 0.25
Standard C: 0.2 gramme of
hydrogen chloride / Nm
3

(d) Hydrogen chloride Any source Standard A: 0.6
Standard B: 0.5
hydrogen chloride / Nm
3

(e) Fluorine, hydrofluoric
acid, or inorganic
fluorine compound
Manufacture of aluminium from
alumina
Equivalent of:
hydrofluoric acid/Nm
3
of effluent
gas

(f) Fluorine, hydrofluoric
acid, or inorganic
fluorine compound
Any source other than
manufacture of aluminium from
alumina as in (e) above
Equivalent of:
Standard A: 0.15
Standard B: 0.125
hydrofluoric acid/Nm
3
of effluent
gas

(g) Hydrogen sulphide Any source Standard A: 6.25
Standard B: 5.00
Standard C: 5.00
Parts per million volume for
volume


5-66

Table 5.6.2: Permissible Gaseous Emissions Limits from any Trade, Industry or Process
(Environmental Quality (Clean Air) Regulations, 1978 (contd)

Substance Emitted Sources of Emission Standards

(h) Oxide of nitrogen Manufacture of nitric acid Equivalent of:
Standard A: 4.60
Standard B: 4.60
Standard C: 1.7 and effluent gas
substantially colourless gramme of
sulphur trioxide / Nm
3
.

(i) Oxides of nitrogen Any source other than
combustion processes and
manufacture of nitric acid as in
(h) above
Equivalent of:
Standard A: 3.0
Standard B: 2.5
Standard C: 2.0 gramme of sulphur
trioxide/Nm
3

(j) Solid Particles

Solid Particles
Fuel Burning Equipment /
industrial plant used for heating
of metals (other then cold blast
foundry cupolas.

Fuel Burning Equipment /
industrial plant used for other
than heating of metals
Standard A: 0.30 gm/Nm
3

Standard B: 0.25 gm/Nm
3

Standard C: 0.20 gm/Nm
3

3

3

3

(k) Metals & Metallic
Compounds
Mercury
Cadmium
Lead
Antimony
Arsenic
Zinc
Copper
Standard A

0.02
0.025
0.04
0.04
0.04
0.15
0.15
Standard B

0.01
0.015
0.025
0.025
0.025
0.1
0.1

Standard C

0.01
0.015
0.025
0.025
0.025
0.1
0.1

(l) Asbestos and Free Silica For any trade, industry or
process which emits or
discharges dust or any solid
particles containing asbestos or
free silica the concentration of
air impurities shall not exceed
the following:
3

3

3


5-67

For purposes of this study, RMAQG is used as the criteria for ground level
concentration of the pollutants under assessment and where compounds are not
covered by the RMAQGs (i.e. HF and H
2
SO
4
), the World Health Organisation
(WHO) Air Quality Guidelines and the Office of Environmental Health Hazard
Assessment (OEHHA, 2005)
5
Chronic Reference Exposure Levels.

The primary aim of the WHO guidelines is to provide a basis for protecting public
health from adverse effects of air pollution and for eliminating, or reducing to a
minimum, those contaminants of air that are known or likely to be hazardous to
human health and well-being. These guidelines are intended to provide background
information in making assessments of risk. They are intended as guidelines, rather
than strict standards, but also aim to provide a basis for setting standards or limit
values for air pollutants by setting levels below which exposure for a given period of
time does not constitute a significant health risk.

The OEHHA guidelines have been applied for the compounds not covered by the
RMG or WHO guidelines. The OEHHA guidelines are typically based upon values
published by other reputable authorities rather than being developed from first
principles based on results of actual toxicological studies. The OEHHA guidelines
are, however, considered useful for this assessment in that they are one of the few
sources that publish acute health protective guidelines for a wide list of compounds.
The criteria used for the Advanced Materials Plant emissions operational phase are
presented in Table 5.6.3.

Table 5.6.3: Ambient Air Quality Criteria for the Advanced Materials Plant

Air Quality Guideline (g/m
3
) for Different Averaging
Times
1
Compoun
d
1 hour 24 hour Annual
Reference
350 105 - RMG
SO
2

- - 50 WHO
HF 240 - 0.5 OEHHA
H
2
SO
4
120 - 1 OEHHA
PM
10
- 150 50 RMG
Notes: 1. Referenced to a temperature of 0C and absolute pressure of 101.3 kPa.

5
Office of Environmental Health (OEH) (1999): 1999 Update Arizona Ambient Air Quality Guidelines.
Report prepared for the Arizona Department of Environmental Quality.


5-68

The American Conference of Governmental Industrial Hygienists (ACGIH)
recommends Short-Term Exposure Limits (STELs) for a number of chemical
substances which workers may be exposed to within an occupational setting. STELs
are defined as a 15 minute Time Weighted Average (TWA) which should not be
exceeded at any time during a workday (ACGIH, 2002). The STELs relevant to this
study are presented in Table 5.6.4 below.

Table 5.6.4: Short-Term Exposure Levels

Compound STEL (g/m
3
) Reference
SO
2
14,300
H
2
SO
4
3,000
ACGIH



During the construction phase of the project, the ambient air quality will be
potentially impacted by fugitive dust emissions and exhaust emissions. These
emissions will reduce visibility and reduce the prevailing ambient air quality.

Construction activities most likely to result in the emission of fugitive dusts include:

Site preparation works such as excavation, levelling, compaction and trenching;
Movement of heavy construction vehicles and machinery within the site and
during transportation operations;
Material handling (delivery, unloading and use of construction aggregates and
structural fill); and
Material/soil tracked out of the site and deposited on local roads.

The exhaust emissions emitted from vehicle and machinery engine exhaust emissions
will contain NO
x ,
SO
x ,
CO, volatile organic compounds (VOC), particulates and
smoke.

5-69


Construction works may potentially impact the ambient air quality and public health
as well as generate significant nuisance effects if left uncontrolled. The main concern
in terms of air quality impacts is the emission of fugitive dust from the construction
works area, and to a lesser extent emission from vehicles and construction machinery
stationed on-site. Fugitive dust emissions will be a concern especially during dry
weather. Although these impacts are localised and short-termed, the local air quality
will be significantly affected during the dry weather if no control measures are put in
place, and may worsen the frequent haze conditions experienced in the state and
country.

a. Fugitive Dust

The amount of fugitive dust stirred into the atmosphere is dependent on the following
factors:

Frequency of operations;
Ambient weather conditions;
Soil conditions (including the particle size distribution, silt and moisture
content);
Total area of land to be cleared;
Quantities of materials handled;
Number of vehicles working, routing and transit speeds; and
Transport of fill material.

The dispersion of particulates is expected to vary daily depending of the factors
identified above. For example, under moderate wind speeds (5.5 m/s 7.9 m/s),
particulates larger than ~ 100 m would be expected to settle out within ~ 10 m
whereas those in the size range of 30 - 100 m in diameter will undergo impeded
settling due to atmospheric turbulence and settle out within 100 m of the source.
Smaller particles, especially PM
10
(size lesser than 10 m) have a much lower
gravitational settling rate and are more likely to have their settling rate retarded by
atmospheric turbulence
6
. Dust impacts in this instance are significant to the workforce
involved.

In the case of mobile dust sources, significant quantities of dust may be stirred into
the ambient air by heavy vehicles moving in and out of the site for the delivery of
ready-mix concrete, construction machinery and off site disposal of construction
wastes. The action of wheels on the road surface causes pulverisation of soil particles
and the air turbulence created behind the vehicle that exceeds 5 m/s will potentially
disperse the fine soil particles to a significant distance.

6
AP-42: Compilation of Air Pollution Emission Factors Volume 1, Stationary Sources, US

5-70

The principal meteorological characteristics which influence the generation of
fugitive dust and its subsequent impact on the surrounding environment are rainfall
and wind speed/direction, and to a lesser extent atmospheric stability and relative
humidity. The plant site experiences prevailing winds from the north ~ 25% of the
time and southwest ~11% of the time annually. However, wind speeds are generally
low occurring below 3.3 m/s for 79% of the time and rarely exceeding 5.4 m/s (20
km/h). Higher wind speeds are typically associated with winds from the north,
northeast, east and southwest.

The frequent occurrence of rainfall (The average annual rainfall recorded at the
station over the period 19512005 is 2,957 mm with an average of 189 rainy days
annually) and the low wind speeds (mean of 3 m/s) at the plant site will tend to reduce
fugitive dust entrainment from sources (e.g. stockpiled materials etc.), but will have
limited effects on entrainment from mobile dust sources (e.g. mobile plant, spoil
transfer operations).

Based on the above, the impacts are predicted to be generally localised within an
estimated 100 m radial distance of the works area, with the implementation of
standard dust control measures within the construction works site. The impacts arising
from construction activities at the proposed site is therefore anticipated to be short-
term, lasting during the construction phase.

Regionally, particulates especially the finer material PM
10
will potentially contribute
to haze formation during the drier and calmer months of the year. Incidences of haze
in Pahang (and Malaysia) have been prevalent in recent years, giving rise to
respiratory and eye related health problems.

b. Exhaust Emissions

Apart from dust particulates, the ambient air quality may also be reduced due to the
increase of other pollutants such as sulphur dioxide and nitrogen oxides released from
exhaust emissions of trucks and other diesel powered construction
machinery/equipment within the site. Typical air emissions from construction
equipment are presented in Table 5.6.5.

Table 5.6.5: Emission Factors for Construction Equipment

Equipment CO (g/hr) VOC (g/hr) NO
x
(g/hr) SO
x

(g/hr)
Particulate
s (g/hr)
Tracked-type tractor 157 55 571 62 51
Wheeled-type tractor 1623 85 576 41 62
Scraper 568 128 1741 210 184
Motor Grader 69 18 324 39 28
Wheeled loader 260 91 859 83 78
Truck 817 87 1889 206 116


5-71

Impacts arising from exhaust emission from construction plant and vehicles will
depend on the number of vehicles and plant stationed on site. Details on the number
and type of construction machinery had not been firmed up at the time of reporting.
However, the impacts arising can be effectively mitigated with proper and regular
maintenance of the emission sources which would prevent the generation of excessive
noxious emissions and black smoke.


The potential air quality impacts arising from the plant site during construction works
will be mitigated by observing standard dust suppression measures as described
below.

Carrying out regular surface damping or wetting on general site areas, stockpiled
fill and aggregates especially during dry ambient conditions. Effective wetting of
at least the initial 6 cm of the top soil is necessary. This would bind the loose soil
particles, increase its effective size and weight, and reduce the amount of fugitive
dust generated;

Providing side enclosure and covering of any aggregates or stockpiles;

Ensuring that all hardstanding areas and access roads within the site remain wet
during use;

Ensuring construction vehicles moving in/out of the site do not track soil off-site
and deposit soil on public roads (the Gebeng Bypass and the Kuantan-Kemaman
Road (FR 3)) by providing wheel-washing facilities/trough at the ingress/egress
points. These facilities will be equipped with (1) a temporary concrete
hardstanding of sufficient size to accommodate a standard sized vehicle and
equipped with a sump; and (2) high pressure water jets. The location of the wheel
wash trough is presented in Exhibit 5.2.1 (under the Surface Water section).

All vehicles operating within the plant site and especially within the construction
works area and the ingress/egress points will adhere to speed limits not exceeding
30 km/hr.

A 50 m road stretch on the public road before and after each ingress/egress point
into the site will be wetted regularly to minimise dust emissions from the surface
of the road.

All construction vehicles transporting dusty materials should be secured with
tarpaulin sheets to prevent the escape of fugitive dust.

5-72

Open burning on the site premises is strictly prohibited on-site. All construction
spoil must be transported to approved disposal sites by licensed contractors.

The control of vehicular emissions can be achieved by observing good construction
practice procedures such as:

Turning of equipment when not in use;
Lorries/trucks waiting for more than 10 minutes should turn off their engines; and
Regular maintenance of construction vehicles/equipment.



In the operational phase of the Advanced Materials Plant, air emission sources
identified within the Cracking & Separation Plant include the following:

Tunnel furnace used for product calcination;
Boiler used for steam generation; and
Waste gas treatment system (wet scrubber).

Tunnel Furnace and Boiler

In the product calcination stage within the Cracking & Separation Plant, Lanthanum
oxide and Didymium oxide will be produced by calcination of the oxalate compounds
of these metals at a temperature of 900
0
C in a tunnel furnace which will be powered
by natural gas.

Similarly, the boiler used for steam generated within the plant will be powered by
natural gas.

Natural gas is the cleanest of all the fossil fuels. Composed primarily of methane, the
main products of the combustion of natural gas are carbon dioxide and water vapour
with very small amounts of sulphur dioxide and nitrogen oxides, virtually no ash or
particulate matter, and lower levels of carbon dioxide, carbon monoxide, and other
reactive hydrocarbons. The emissions from the calcinations process and the boiler will
be emitted directly to the atmosphere without any form of pre-treatment. No air
quality impacts envisaged from these emissions sources.

5-73

Waste Gas Treatment System

The primary source of air emissions arising from the plant during the operational
phase will be the waste gas scrubber system at the Cracking & Separation Plant. The
layout and cross sectional view of the treatment system are provided in Exhibits 5.6.1
and 5.6.2.

In the Cracking & Separation Plant, the lanthanide concentrate will be mixed with
sulphuric acid (98%), blended for a set time and the mixture/slurry will then flow into
two (2) rotary kilns for intensive roasting at 40050 (
0
C) for a period of 2.5 hours.
The roasted products will comprise roasted concentrate and waste (tail) gas. As the
sulphuric acid will be complete evaporated, during the cracking process, the exhaust
gas will not carry any liquid aerosols.

The kilns are fuelled by natural gas and the gas flow will be automatically controlled
by the temperature at the hot end of the kiln. Two (2) fuel gas burners are proposed
for each rotary kiln.

The waste gas will be conveyed to a waste gas scrubber system for treatment prior to
release to the atmosphere. The treated gas is expected to contain small quantities of
sulphur dioxide (SO
2
), hydrogen fluoride (HF), sulphuric acid mist and particulate
matter (PM).

High concentrations of SO
x
in the atmosphere, with levels exceeding 40 ppb or 105
g/m
3
, will significantly impact humans, animals and agricultural activities within the
impact zone in the following manner:

Increased incidences of respiratory diseases amongst residents;
Lowering of agricultural produce; and
Increased acidity in the rain water which will subsequently affect terrestrial and
aquatic flora/fauna.

Hydrogen fluoride (HF) readily dissolves when mixed with water. It has the potential
to be transported and subsequently deposited as acid rain. Concentrated hydrogen
fluoride is very corrosive and would badly burn any plants, birds or land animals
exposed to it. The concentrations of hydrogen fluoride found in close proximity to
sources may adversely affect some species of plants. Small quantities of hydrogen
fluoride will be neutralised by the natural alkalinity in aquatic systems and larger
quantities may lower the pH for extended periods of time. However, fluorides are not
expected to bioaccumulate. Acute (short-term) inhalation exposure to gaseous
hydrogen fluoride can cause severe respiratory damage in humans, including severe
irritation and pulmonary edema.

5-74


As the emission from the waste gas treatment system (wet scrubber) is the primary air
pollution source, an air dispersion modelling was carried out for this point source.

In developing the air dispersion model, two operational modes have been identified
for the proposed plant, namely (1) normal and (2) emergency operations. Under
normal operations, small quantities of sulphur dioxide (SO
2
), hydrogen fluoride (HF),
sulphuric acid mist (H
2
SO
4
) and particulate matter (PM) will be emitted from the
waste gas treatment system following treatment of the kiln off-gas. Under emergency
operations, SO
2
and H
2
SO
4
mist will be emitted from standby caustic scrubbers
following treatment of emissions from the kilns operating in shutdown mode. A
summary of the operational modes defined for the proposed plant is provided in
Table 5.6.6.

Table 5.6.6: Proposed Advanced Materials Plant Summary of Operational
Modes

Operating Mode Sources
Pollutants
Emitted
Description
1 Kiln
One rotary kiln in operation. Emissions are treated
within the waste gas scrubber system (A) prior to
discharge to atmosphere.

2 Kilns
Two rotary kilns in operation. Emissions from
each kiln are treated within the waste gas scrubber
system (A) prior to discharge to atmosphere via a
single stack.

Normal
4 Kilns
SO
2

HF
H
2
SO
4
mist
PM
Four rotary kilns in operation. Emissions from
each pair of kilns are treated within separate waste
gas scrubber systems (A and B) prior to discharge
to atmosphere via two individual stacks.

1 Emergency
Scrubber
One emergency scrubber in operation. Emissions
from a single kiln in shutdown mode are treated
within a standby caustic scrubber and discharged
to atmosphere via a single stack.

2 Emergency
Scrubbers
Two emergency scrubbers in operation. Emissions
from each of the two kilns in shutdown mode are
treated within individual standby caustic scrubbers
and discharged to atmosphere via two separate
stacks.

Emergency
4 Emergency
Scrubbers
SO
2

H
2
SO
4
mist

Four emergency scrubbers in operation. Emissions
from each of the four kilns in shutdown mode are
treated within individual standby caustic scrubbers
and discharged to atmosphere via four separate
stacks.


5-75

Three events have been identified by the Project Proponent which would trigger
emergency operations:

1. Utility power failure (external);
2. Plant system power failure (internal); and
3. Loss of liquid-flow to the waste gas scrubber system.

In each of the three emergency events, kiln feed will cease whilst primary and
secondary combustion air fans continue to operate to maintain a high gas flow rate
that aids cooling of the kiln and dispersion of emitted gas. The evolution of SO
2
, SO
3

and H
2
SO
4
from the kiln contents may continue for up to 20 hours following a
shutdown although the rate of evolution drops sharply during the first hour.

Emergency operations due to an external power failure are expected to occur once per
annum for a duration of 4-hours, while emergency operations due to an internal power
failure are expected to occur once every 25 years for a duration of 21-hours. All
operational kilns will be impacted in both cases.

Emergency operations due to a loss of liquid-flow to the waste gas scrubber system
are also expected to occur once per annum for a duration of 4-hours. However, while
only a single operational kiln is expected to be impacted at any one time, all kilns are
predicted to be impacted once per annum.

For the purposes of the air dispersion modelling, it has been assumed that the
emissions of particulate matter are all within the PM
10
size fraction. This assumption
is conservative and is likely to result in an over prediction of the ground level
concentrations (GLCs) of PM
10
compared to what would be expected to occur in
reality.

Further details of the emission information and release parameters for the proposed
plant as used in the air dispersion modelling for the Normal and Emergency operating
scenarios is provided in the proceeding sections.

For the purposes of the air dispersion modelling, it has been assumed that the
emissions of particulate matter will all be within the PM
10
size fraction. This
assumption is conservative and is likely to result in an over prediction of the ground
level concentrations of PM
10
compared to what would be expected to occur in reality.

To determine the dispersion pattern of the pollutants released from the emissions of
the waste gas treatment system and to quantify their respective concentrations in the
atmosphere, the BREEZE Industrial Source Complex Short Term Version 3 with
Plume Rise Enhancements (BREEZE ISC3 Prime) air dispersion model was used to
predict the potential ground level impacts arising from emissions of the waste gas
scrubber stack.

5-76

The BREEZE ISC3 Prime model was used to predict the maximum GLCs over 10-
minute, 1-hour, 24-hour and annual averaging periods to correspond with the relevant
ambient air quality criteria for each of the modelled compounds. Short-term average
(15 minute) GLCs were calculated from 1-hour concentrations for the Emergency
operations scenario for compounds where STELs apply using the Hanna, Briggs and
Hosker Power Law
7
.

a. Assessment Methodology

Synoptic Meteorological Data

A site specific meteorological file for the project area was generated using The Air
Pollution Model (TAPM). Local wind fields were predicted by this model based on
synoptic meteorology, local topography and land surface characteristics (i.e. soil type,
vegetation cover). TAPM was developed by the Australian Commonwealth Scientific
and Industrial Research Organisation (CSIRO) and consists of coupled prognostic
meteorological (i.e. using the larger-scale meteorology provided by synoptic analyses)
and air pollution concentration components. The synoptic meteorological data is
derived from GASP (Global Analysis and Prediction) analysis data used by the
Australian Bureau of Meteorology (BoM).

Synoptic meteorological data for the year 2005 for Malaysia were used as input into
the TAPM model. A windrose derived from the TAPM generated data for the 2005
period is presented in Exhibit 5.6.4 illustrating light winds between 1.5 m/s and 3 m/s
occur most frequently, for approximately 60% of the year. Stronger winds between 3
m/s and 4.5 m/s tend northeasterly and south-southwesterly and are experienced for
close to 26% of the year, while winds greater than 4.5 m/s are less frequent and are
predominantly north-northeasterly. The strong influence of the southwest and
northeast monsoon periods on meteorological conditions is also evident in the annual
windrose.

Model Parametisation

Table 5.6.7 presents a summary of the emission information and release parameters
for the waste gas scrubber and emergency scrubber stacks at the proposed plant, as
used in the air dispersion modelling for the normal and emergency operating
scenarios. Information on the emissions for the plant during the operational phase
was provided by the Project Proponent. The stack height and exit velocity used in the
study were developed based on information provided by the engineering consultant
and preliminary modelling results.

7
Hanna, Briggs and Hosker Power Law: GLC[n hrs] =GLC[m hrs] x [m/n]
0.2


5-77

The emission of H
2
SO
4
from the caustic scrubber(s) operating under emergency
conditions is expected to decrease sharply during the first 2-minutes of release, before
continuing to slowly decrease during the following 9-hours of release (if the
emergency release is of that duration, although most emergency releases are expected
to last less than 4 hours). In order to capture the acid decay rate within the air
dispersion modelling, the average emission rate for the first 15-minutes of release (9.9
g/s per emergency scrubber) was adopted to predict the short-term (15-minute) H
2
SO
4

GLCs and the average emission rate for the first 1-hour of release (7.8 g/s per
emergency scrubber) was adopted to predict the 1-hour H
2
SO
4
GLCs. For emergency
releases lasting longer than 1-hour these emissions rates are very conservative.

The information in Table 5.6.7 also indicates the emission concentrations under
normal operations (at standard temperature and pressure (STP)) comply with the
DoEs Emission Standards for Stationary Sources outlined in Table 4. Note emissions
released under emergency operations are not subject to the DoEs Emission Standards
and the frequency of such an event occurring is considered low.


5-78

Table 5.6.7: Emissions Information and Stack Release Parameters Normal and Emergency Operations

Normal Operations Emergency Operations
Parameters Units WGTS
[1]
A 1
Kiln
WGTS
[1]
A 2
Kilns
WGTS
[1]
B 2
Kilns
Scrubber 1 Scrubber 2 Scrubber 3 Scrubber 4
Easting m 319530 319530 319542 319492 319497 319502 319507
Northing m 442819 442819 442780 442810 442797 442780 442766
Stack height m 55 55 55 40 40 40 40
Stack diameter m 1.2 1.2 1.2 0.6 0.6 0.6 0.6
Exit temp. C 70 70 70 50 50 50 50
Exit velocity m/s 7.5 15 15 15 15 15 15
Pollutant Emission Rates
SO
2
g/s 3.5 6.9 6.9 1.6 1.6 1.6 1.6
HF g/s 0.3 0.7 0.7 na na na na
H
2
SO
4
mist g/s 0.3 0.7 0.7 9.9/7.8
[2]
9.9/7.8
[2]
9.9/7.8
[2]
9.9/7.8
[2]

PM
10
g/s 0.7 1.4 1.4 na na na na
Emission Concentrations at STP
HF g/Nm
3
0.05 0.05 0.05 na na na na
H
2
SO
4
mist g/Nm
3
0.05 0.05 0.05 na na na na
PM
10
g/Nm
3
0.1 0.1 0.1 na na na na
Notes
1. Waste Gas Treatment System (WGTS)
2. 9.9 g/s adopted to calculate 15-minute GLCs and 7.8 g/s adopted to calculate 1-hour GLCs


5-79

b. Model Results Normal Operations

Table 5.6.8 presents the maximum predicted GLCs resulting from the proposed plant
under normal conditions with 1, 2 or 4 kilns in operation. Also presented is the
percentage of the STELs and AAQ guidelines that the predicted concentrations
represent. Where maximum predicted GLCs are greater than 50% of the applicable
guidelines, contours of the predicted GLCs for the relevant scenario have been
produced and are presented as Exhibits 5.6.4 and 5.6.5.

Table 5.6.8: Maximum Predicted Ground Level Concentrations for Normal
Operations

The results presented in Table 5.6.8 show that the predicted GLCs of SO
2
, HF, H
2
SO
4

and PM
10
are below each of the applicable STELs and AAQ guidelines. Further
details for each of the modelled compounds are provided below.
Maximum Predicted GLCs (g/m
3
)
Pollutant
Averaging
Period
AAQ Guideline
(g/m
3
) 1 Kiln 2 Kilns 4 Kilns
500 101 139 283
10-minute
% Guideline 20% 28% 57%
14,300 93 128 261
15-minute
[1]

% Guideline 1% 1% 5%
350 71 97 198
1-hour
% Guideline 20% 28% 57%
105 10 17 33
24-hour
% Guideline 10% 16% 31%
50 1.3 1.8 3.6
SO
2

Annual
% Guideline 2.6% 3.7% 7.2%

240 7.0 9.7 20
1-hour
% Guideline 2.9% 4.1% 8.2%
0.5 0.1 0.2 0.4
HF
Annual
% Guideline 25% 37% 72%

3,000 9.2 13 26
15-minute
[1]

% Guideline 0.3% 0.4% 0.9%
120 7.0 9.7 20
1-hour
% Guideline 5.8% 8.1% 16%
1 0.1 0.2 0.4
H
2
SO
4

Annual
% Guideline 13% 18% 36%

150 2.1 3.3 6.5
24-hour
% Guideline 1.4% 2.2% 4.3%
50 0.3 0.4 0.7
PM
10

Annual
% Guideline 0.5% 0.7% 1.4%
Notes
1. Maximum predicted 15-minute GLCs have been compared to the STEL, applicable onsite.

5-80

Sulphur Dioxide

Maximum predicted 15-minute SO
2
GLCs remain well below the STEL applicable
onsite, representing no more than 5% of the guideline value for each of the normal
operating scenarios modelled.

The maximum predicted 10-minute and 1-hour SO
2
GLCs are no greater than 57% of
the corresponding AAQ guidelines for 1, 2 or 4 kilns operating under normal
conditions, while the maximum predicted 24-hour SO
2
GLCs are no greater than 31%
of the 24-hour guideline for any of the modelled normal operating scenarios. Annual
GLCs also remain well below the annual AAQ guideline, representing no more than
7.2% of the guideline value for 1, 2 or 4 kilns operating under normal conditions.

The contours of the maximum predicted 1-hour SO
2
GLCs
8
for 4 kilns under normal
operation (5.6.4) show that the maximum concentrations are predicted to occur within
close proximity to the southern boundary of the proposed plant.

Hydrogen Fluoride

The maximum predicted 1-hour HF GLCs represent no more than 9% of the 1-hour
AAQ guideline for 1, 2 or 4 kilns operating under normal conditions. Annual GLCs
also remain below the applicable guideline, representing no more than 37% of the
annual guideline for 1 or 2 kilns operating under normal conditions, while the annual
average GLC predicted for 4 kilns operating under normal conditions represents 72%
of the annual guideline.

The contours of the annual average HF GLCs predicted for 4 kilns under normal
operation (Figure 5.6.5) indicate the maximum concentrations are predicted to occur
within a localized area close to the north-east boundary of the proposed plant.

Sulphuric Acid Mist

Maximum predicted 15-minute H
2
SO
4
onsite, representing no more than 5% of the guideline value for any of the modelled
normal operating scenarios.

The maximum predicted 1-hour H
2
SO
4
GLCs represent no more than 16% of the
relevant AAQ guideline for 1, 2 or 4 kilns operating under normal conditions. Annual
H
2
SO
4
GLCs also remain below the applicable guideline, representing no more than
36% of the annual guideline for 1, 2 or 4 kilns operating under normal conditions.

8
As the maximum predicted 10-minute SO
2
GLCs were calculated from the maximum predicted 1-hour SO
2

GLCs, the GLCs for each averaging period are expected to maintain similar dispersion patterns. Contours of the
10-minute SO
2
GLCs can therefore be scaled against contours of the 1-hour SO
2
GLCs.

5-81

Particulate Matter

The maximum predicted 24-hour PM
10
GLCs remain well below the AAQ guideline,
representing no more than 4.3% of the guideline value for 1, 2 or 4 kilns operating
under normal conditions, while annual PM
10
GLCs represent no more than 1.4% of
the annual guideline for any of the modelled normal operating scenarios.

c. Model Results Emergency Operations

Table 5.6.9 presents the maximum predicted GLCs resulting from the proposed plant
under emergency conditions with 1, 2 or 4 emergency scrubbers in operation. Also
presented are the percentages of the AAQ guidelines and STELs that the predicted
concentrations represent. Where the maximum predicted GLCs are greater than 50%
of the applicable guidelines, contours of the predicted GLCs for the relevant scenario
have been produced and are presented as Exhibits 5.6. through 5.6.12.

As emergency operating conditions are expected to be of short duration (release
events from the emergency scrubbers being no longer than 21 hours (once very 25
years) but typically less than four hours) the maximum predicted GLCs have been
presented for short-term averaging periods only.

Table 5.6.9: Maximum Predict Ground Level Concentrations for Emergency
Operations

Maximum Predicted GLCs (g/m
3
)
Pollutant
Averagin
g Period
AAQ Guideline
(g/m
3
) 1 Scrubber 2 Scrubbers 4 Scrubbers
500 129 254 447
10-minute
% Guideline 26% 51% 89%
14,300 119 234 412 15-minute
[1]
% Guideline 0.8% 1.6% 2.9%
350 90 177 312
1-hour
% Guideline 26% 51% 89%
105 19 38 79
SO
2

24-hour
% Guideline 18% 36% 76%

3,000 730 1433 2524 15-minute
[1]
% Guideline 24% 48% 84%
120 431 846 1490
H
2
SO
4

1-hour
% Guideline 359% 705% 1242%
Notes
1.
Maximum predicted 15-minute GLCs have been compared to the STEL,
applicable onsite.
2. Bold indicates an exceedence of the corresponding guideline.


5-82

The results presented in Table 5.6.9 show that the predicted GLCs of SO
2
are below
the applicable STEL and AAQ guidelines and for 1, 2 and 4 scrubbers operating
under emergency conditions. Predicted GLCs of H
2
SO
4
are also below the 15-minute
STEL, however exceedences of the 1-hour H
2
SO
4
AAQ guideline are predicted for
each of the modelled scenarios. Further details for each of the modelled compounds
are provided below.

Sulphur Dioxide

The maximum predicted 10-minute, 1-hour and 24-hour SO
2
GLCs are no greater
than 51% of the corresponding AAQ guidelines for 1 or 2 emergency scrubbers
operating under emergency conditions. The maximum SO
2
GLCs predicted for 4
emergency scrubbers operating under emergency conditions are no greater than 89%
of the 10-minute or 1-hour AAQ guidelines and remain less than 76% of the 24-hour
guideline. It should be noted that these maximum predicted concentrations are
extremely conservative as they have been predicted assuming that the emergency
scrubbers operate continuously. In reality they operate for approximately 0.2% of the
time and the probability of an emission occurring under the conditions required to
produce the maximum concentrations is very low.

The contours of the maximum predicted 1-hour SO
2
GLCs
9
for 2 emergency
scrubbers operating under emergency operations (Exhibit 5.6.6) and for 4 emergency
scrubbers operating under emergency operations (Exhibit 5.6.7) show that the
maximum concentrations are predicted to occur within close proximity to the
northeast boundary of the proposed plant. Contours of the maximum predicted 24-
hour SO
2
GLCs for 4 emergency scrubbers in operation (Exhibit 5.6.8) also show that
the maximum concentrations are predicted to occur within a similar location.

Maximum predicted 15-minute SO
2
onsite, representing no more than 3% of the guideline value for each of the emergency
operating scenarios modelled.

The SO
2
GLCs predicted for the proposed plant operating under emergency
conditions are considered conservative as the modelling assumes continuous
operation of the emergency scrubbers, while the total number of operational hours is
not expected to exceed 20-hours over the course of a year (for no more than 4-hours at
a time) or a one in 25 year release event lasting 21-hours. Furthermore, SO
2
emissions
from each of the emergency scrubbers have been modelled at a steady rate, although
SO
2
emission rates are expected to decay alongside H
2
SO
4
emission rates,
compounding the level of conservatism within the predicted GLCs.

9
As the maximum predicted 10-minute SO
2
GLCs were calculated from the maximum predicted 1-hour SO
2

GLCs, the GLCs for each averaging period are expected to maintain similar dispersion patterns. Contours of the
10-minute SO
2
GLCs can therefore be scaled against contours of the 1-hour SO
2
GLCs.

5-83

Sulphuric Acid Mist

Maximum predicted 15-minute H
2
SO
4
GLCs remain below the STEL applicable
onsite, representing no more than 48% of the guideline value for 1 or 2 emergency
scrubbers operating under emergency conditions and no more than 84% of the
guideline value for 4 emergency scrubbers operating under emergency conditions.
Contours of the maximum predicted 15-minute H
2
SO
4
GLCs for 4 emergency
scrubbers in operation (Exhibit 5.6.9) show that the maximum concentrations are
predicted to occur within close proximity to the northeast boundary of the proposed
plant.

Maximum predicted 1-hour H
2
SO
4
GLCs are predicted to exceed the corresponding
AAQ guideline for 1, 2 and 4 emergency scrubbers operating under emergency
conditions, by up to 12 times. Contours of the maximum predicted 1-hour H
2
SO
4

GLCs for 1, 2 and 4 emergency scrubbers in operation (Exhibits 5.6.10, 5.6.11 and
5.6.12 respectively) show that exceedences of the 1-hour H
2
SO
4
AAQ guideline value
of 120 g/m
3
occur roughly within a 4km radius from the proposed plant with a single
emergency scrubber in operation and extend throughout the majority of the modelled
domain with 4 emergency scrubbers in operation. As for SO
2
, it should be noted that
these maximum predicted concentrations are extremely conservative as they have
been predicted assuming that the emergency scrubbers operating continuously. In
reality they operate for approximately 0.2% of the time and the probably of an
emission occurring under the conditions required to produce the maximum
concentrations is very low.

Further analysis of the modelling results indicates that the maximum frequency of
exceedence of the 1-hour H
2
SO
4
AAQ guideline occur for no more than 2.6% of the
year (231-hours) for 1 emergency scrubber in operation, 6.9% of the year (605-hours)
for 2 emergency scrubbers in operation and 9.6% of the year (841-hours) for 4
emergency scrubbers in operation. The contours of the frequency of exceedence of the
1-hour H
2
SO
4
AAQ guideline for 1, 2 and 4 emergency scrubbers in operation
(Exhibits 5.6.13, 5.6.14 and 5.6.15 respectively) show that the highest number of
exceedence events are predicted to occur within close proximity to the northeast
boundary of the proposed plant.

The H
2
SO
4
GLCs predicted for the proposed plant operating under emergency
conditions are considered conservative as the modelling assumes continuous
operation of the emergency scrubbers, while the total number of operational hours for
any one kiln is not expected to exceed 8-hours over the course of a year (for no more
than 4-hours at a time) or a one in 25 year release event lasting 21-hours.

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A summary of the overall probability of an exceedence of the 1-hour H
2
SO
4
guideline
is presented in Table 5.6.10, for each of the modelled scenarios. The overall
probability, as calculated from the combination of an emission occurring and the
probability of an exceedence occurring, under a worst case scenario (i.e. 4 emergency
scrubbers in operation) is 10.1 x 10
-5
(0.01%), or 101 in a million. For two kilns in
operation, the overall probability of an exceedence of the 1-hour H
2
SO
4
guideline
under emergency

operation is 62.2 x 10
-6
(0.006%) or 62 in a million. Therefore, it is considered that
the risks of unacceptable impacts arising from the proposed plant operating under
emergency conditions are relatively small and manageable within an industrial estate.

Table 5.6.10: Summary of Probability of an Exceedence Event Occurring

2 Kilns 4 Kilns
Operating
Scenario
Frequency of
exceedence of
AAQG
[1]

Frequency of
operations
Probability of
exceedence
Frequency of
operations
Probability of
exceedence
1 Emergency
Scrubber
2.6% of the
year
0.09% (8hrs) of
the year
[2]

0.002%
0.18%(16-hrs) of
the year
[2]

0.47%
2 Emergency
Scrubbers
6.9% of the
year
0.06% (4.84hrs
of the year)
[3]

0.003% NA NA
4 Emergency
Scrubbers
9.6% of the
year
NA NA
0.06% (4.84hrs of
the year)
[3]

0.005%
Total 0.006% 0.01%
Notes
1. Assuming continuous operations
2. 4-hours per emergency scrubber per year
3. Includes both external and internal power failure events

c. Conclusions

The results of the air dispersion modelling indicate that under normal conditions with
1, 2 or 4 kilns in operation, emissions from the proposed plant are predicted to result
in maximum GLCs that are below all of the identified AAQ criteria for SO
2
, H
2
SO
4
,
HF and PM
10
. The maximum predicted 15-minute average GLCs of SO
2
and H
2
SO
4

also remain below the on-site STELs for each of the normal operating scenarios.

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The results also indicate that under emergency conditions with 1, 2 or 4 caustic
scrubbers in operation, emissions from the proposed plant are predicted to result in
maximum GLCs that are below the AAQ criteria and STEL for SO
2
, and the STEL
for H
2
SO
4
. The maximum 1-hour H
2
SO
4
GLCs are however, predicted to exceed the
AAQ guideline of 120 g/m
3
by approximately 3.5 times with 1 scrubber in
operation, by 7 times with 2 scrubbers in operation and by close to 12 times with 4
scrubbers in operation. These exceedences are predicted to occur within an
approximate 4km radius from the proposed plant with a single scrubber in operation
and extend throughout the majority of the modelled domain with 4 scrubbers
operating.

It should be noted that these predicted maximum H
2
SO
4
concentrations are extremely
conservative as they have been determined assuming that the emergency emissions
occur continuously throughout the year, whereas the total cumulative frequency of all
of the emergency cases identified is approximately 0.2% of the time.

Further analysis of the modelling results for the emergency emissions indicates that
the maximum frequency of exceedence of the 1-hour H
2
SO
4
AAQ guideline,
assuming continuous operations, occurs for no more than 9.6% of the year (841-
hours) with 4 emergency scrubbers in operation. However, this emergency emission
scenario is only expected to occur for 0.06% of the time (i.e. external power failure of
4-hours/year and internal power failure for 21 hours once every 25 years). The
combination of the probability of the total power loss emergency scenario occurring
and the probability of this resulting in an exceedence of the AAQ guideline results in
an overall probability of this scenario resulting in an exceedence of the H
2
SO
4
AAQ
guideline of 5.3 x 10
-5
, or 53 in a million.

Similar analysis undertaken for the other identified emergency release scenarios
indicates that the overall probability of an exceedence of the 1-hour H
2
SO
4
guideline
(assuming all three events which trigger an emergency emission scenario occur), with
4 emergency scrubbers in operation, is 10.1 x 10
-5
, or 101 in a million. For two kilns
in operation, the overall probability of an exceedence of the 1-hour H
2
SO
4
guideline
under emergency operation is 62.2 x 10
-6
, or 62 in a million. Therefore, it is
considered that the risks of unacceptable impacts arising from the proposed plant
operating under emergency conditions are relatively small and manageable within an
industrial estate.

In summary, the air dispersion modelling indicates that the atmospheric emissions
from the proposed plant are predicted to result in:

maximum GLCs of SO
2
, H
2
SO
4
, HF and PM
10
below all of the applicable
AAQ guidelines and STELs, across the model domain, for 1, 2 or 4 kilns
operating under normal conditions and where the highest concentrations are
predicted to occur in relative close vicinity to the plant;

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maximum GLCs of SO
2
below all the applicable AAQ guidelines and STELs,
across the model domain, for 1, 2 or 4 caustic scrubbers operating under
emergency conditions;

maximum GLCs of H
2
SO
4
below the corresponding STEL for 1, 2 or 4 caustic
scrubbers operating under emergency conditions; and

an exceedence of 1-hour H
2
SO
4
AAQ guidelines under emergency operating
conditions, although the worst-case probability of this operating mode
occurring and resulting in an exceedence is 101 in a million.

The results of the air dispersion modelling indicate that the proposed Advanced
Materials Plant is not expected to result in unacceptable air quality impacts under
normal operations for SO
2
, H
2
SO
4
, HF and PM
10
and while exceedences of 1-hour
H
2
SO
4
AAQ guideline are predicted under emergency operating conditions, the
frequency of this occurring is considered low.


The air dispersion modelling has been carried out based on the design stack height of
the proposed waste gas treatment system, the emission rates and pollutant
concentrations of the treated/exit gas, heights of the building structures proposed
within the plant site and local conditions such as the meteorological conditions and
the site (and immediate surrounding) topography. Therefore, in achieving the desired
efficiency and meeting the predicted ground level concentrations of the pollutants
under assessment, i.e. SO
2,
HF, H
2
SO
4
mist and PM
10,
the waste gas scrubber design
parameters will need to be maintained. In the event, there are changes in the design
prior to project implementation, it is recommended that the air dispersion model be re-
run and the assessment reviewed. This is to ensure the ground level concentration for
the pollutants concerned meet the regulatory requirements.

A description of the proposed waste gas scrubber system is provided below.

The main equipment/systems which comprise the proposed waste gas scrubber
comprise the following equipments/systems:

Quench and Venturi Scrubber System
Fans
Absorption Tower Scrubber System
Mist Eliminator
Wet Electrostatic Precipitator
Recirculation systems
Emergency Scrubber System including pumps, scrubber, fans, recycle solution
tanks etc.
H
2
SO
4
Acid Cooler Heat Exchanger

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In the proposed waste gas scrubbing system, the inlet gas from the rotary kilns will
undergo the following stages of treatment:

Gas cooling, sulphuric acid condensation, dust removal, and sulphur trioxide
absorption in the primary Venturi scrubber;
Sulphuric acid mist in the second stage Venturi scrubber;
Sulphur dioxide scrubbing and aerosol polishing in the hydrated lime spray towers
and demister; and
Removal fine sulphuric acid particulates in wet ESP.

The driving force of the exhaust comes from the fan system located downstream of
the Venture scrubbers. The arrangement of the system is (1) individual Venturi
scrubbing systems for each kiln, and (2) common to two kilns are the fans, lime
absorption columns, and wet ESP.

In the primary Venturi scrubber, the gas will be quenched to about 110 C, and then
contacted with concentrated sulphuric acid for the absorption of sulphuric acid,
sulphur trioxide, and removal of the dust particulates present in the inlet gas. The
function of second stage Venturi scrubber is for the removal of sulphuric acid aerosols
and residual dust. The gas is cooled further to about 86 C.

The exhaust streams from the two kilns which have undergone scrubbing in the
parallel Venturi systems will be combined into one common header, upstream of the
forced induction fans, and conveyed into the sulphur dioxide removal spray tower.
Two spray towers have been proposed to operate in series for the removal of sulphur
dioxide with hydrated lime suspension. The scrubbed gas passes through demister
elements at the top of the lime spray towers for removal of droplets..

The scrubbed gas stream finally passes through a Wet Electrostatic Precipitator (wet
ESP), which remove the low concentration of sub micron sulphuric acid mist that may
pass through the venturi scrubbers.

To prevent the release of noxious untreated gas into the atmosphere during upset or
abnormal operations, the necessary safety equipment and instrumentation have been
incorporated into the design of the waste gas treatment system.

An emergency scrubbing system is included for each kiln which will be employed in
the event of power failure or unplanned shutdown of the main waste gas treatment
system. The emergency scrubbing system consists of a packed absorption column
employing sodium hydroxide solution for the scrubbing of sulphur dioxide and
sulphuric acid.

The system will be subjected to periodical maintenance to ensure equipment
reliability and scrubbing efficiency. Monitoring of stack and ambient air quality at the
site boundary and the nearest sensitive receivers will be carried out.

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Overall, the air quality impacts arising from the operation of the plant can be
mitigated by best technological means and reduced to meet regulatory requirements.

5.7 BIOLOGICAL RESOURCES

5.7.1 Construction and Operational Phases

The biological resources affected in the construction phase of the project are:

Terrestrial flora and fauna species at the proposed Advanced Materials Plant site;
and
Aquatic biological resources within Sungai Balok.


a. Terrestrial Flora and Fauna

Construction Phase

As discussed in Chapter Four of this document, prior to the development of the
Gebeng Industrial Estate (GIE) in the 1990s, the area was waterlogged peat swamp
forest. Ecological impacts arising from the land conversion activities have since
occurred at the site. The various species of fauna that inhabited the area are expected
to have perished or migrated to other forested areas nearby while the original
vegetation would have been completely cleared away.

As the site had remained vacant (undeveloped) since the land conversion, it has been
progressively colonised by secondary vegetation comprising the more common, hard
and invasive species. Only sparse vegetation was observed across the site comprising
secondary dryland scrub vegetation with low species diversity. No faunal species of
conservation value is expected to occur. Any remaining vegetation removed is not
significant or of conservation value.

Overall, the impact from the site activities on the terrestrial flora and fauna is not
considered significant.

b. Aquatic System

The aquatic ecosystem within Sungai Balok is an estuarine ecosystem bordered by the
brackish water river ecosystem up to 10 km upstream and by coastal ecosystems at
the river mouth/coastal area. The habitats within this ecosystem include the aquatic
and estuarine habitat, marine (coastal) habitat and benthic habitat. Biological
components in these habitats include:

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Phytoplankton
Zooplankton
Benthos
Fisheries resources

Impacts on the mortality of the aquatic biological resources are primarily associated
with increased suspended solids in the water column of the river.

An increase in suspended solids leads to a reduction in sunlight penetration which
over time decreases photosynthesis, thereby reducing the rate of oxygen production
within the water column. This effect may be further exacerbated during low flow
conditions leading to anoxic conditions. Additionally, a reduction in primary
production (photosynthesis) also diminishes the uptake of nutrients from the water
column. Increase light penetration causes more energy from sunlight to be retained in
the water column creating increases the ambient water temperature. This negatively
impacts oxygen concentrations as oxygen is more soluble in colder waters.

The conditions described above will effect the horizontal and vertical distribution of
organisms in the water body.

As Suspended sediment (SS) fluxes occur naturally in the aquatic environment, fish
have evolved behavioural adaptations to tolerate the increased SS load (e.g, clearing
their gills by flushing water through them). Where SS levels become excessive, fish
will migrate to clearer waters. This level is defined as the tolerance threshold, which
varies from species to species and at different stages of the life cycle. If SS levels
exceed tolerance thresholds, fish are likely to become stressed, injured and may
ultimately die as the increased sediment content in the water column may cause
abrasion of gill filaments and clog opercular cavities.

However, based on personal correspondence with the Department of Fisheries in
Kuantan, the fisheries resources within Sungai Balok are not harvested for
commercial fishing and livelihood. The local fishermen from the main fishing village
of Kampung Balok carry out deep-sea fishing. Only recreational fishing is carried out
along Sungai Balok by anglers. Common names of fish species typically found in the
river include Siakap Puteh, Siakap Merah, Sembilang, Duri and Baung,

5-90


Construction Phase

To minimise the transport of suspended solids into the river, the efficiency of the silt
trap will be maintained by regular desilting using an excavator. The overflow from the
silt trap will be monitored frequently for Total Suspended Solids and Oil & Grease in
accordance to the frequency stipulated by DOE for the construction phase of the
development. The concentration of TSS shall not exceed 50 mg/l and there shall be no
traces of Oil & Grease.

To prevent the washout of other water quality contaminants, a proper materials
management system for the storage of fuel oil, spent oil, grouting materials, paints,
curing compounds, etc. on-site will be necessary (as identified in Section 5.4).

Operational Phase

The impacts to the aquatic biological resources in Sungai Balok are dependent on the
efficient management of process wastewaters and contaminated surface runoff. The
proposed wastewater treatment plant shall be subjected to periodic performance
maintained to ensure its efficiency. The treated effluent from the plant shall comply
with the Standard B discharge limits at all times.

5.8 SOCIO-ECONOMIC ISSUES



Employment of workers to make-up the construction labour force project will be
necessary during the construction phase. Although priority will be given to local
residents working in this sector, employment of foreign labour may be expected in the
event of local labour shortage. If the labour force is housed on-site, proper
accommodation facilities will have to be provided with basic amenities such as
potable water supply, electricity, solid waste disposal and sanitary treatment facilities.

The employment of foreign labour may result in the import of communicable diseases
not indigenous to the area, for example malaria, dysentery and cholera which could
spread to the local residents, in the event of poor hygiene practices, as these diseases
are vector borne or waterborne.

5-91


To prevent undue aberrations with the local community, the nominated EPCM
Contractor when hiring foreign labour must ensure that the workers are legally
registered with the Department of Immigration. This will ensure that these workers
have medical and health certificates testifying to their personal health. Under the
procedures of the department, regular check-ups are necessary for the annual renewal
of their work permits.

To further ensure that socio-cultural impacts are kept to the minimum, contractors are
highly recommended to ensure that the workers are well managed and confined to
their worksite with minimum confrontation with the local community.



a. Overall Regional and National Impacts

Significant long-term positive socio-economic impacts are predicted during the
operational phase of the project. The benefits accrued by the District of Kuantan, the
State of Pahang and the nation are deliberated in Chapter 1 of this document. The key
benefits are:

Inflow of Foreign Direct Investment: The estimated total capital investment
and operating expenditure for this project are significant and the proposed
investment is wholly in line with the Malaysian Governments efforts to
encourage foreign direct investments into the Eastern Corridor of Malaysia.

Export Revenue Foreign Exchange Earnings: The export revenue of the
proposed project constitutes a major contribution to the Malaysian economy and
translates into significant cash inflow into the Malaysian economy that will spur
the growth of not only the Eastern Corridor but the country as a whole.

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Transfer of Technology: Processing of lanthanides is a pioneer activity in
Malaysia and thus the setting up of the Advanced Materials Plant will introduce
new technologies and expertise in lanthanide processing. The Project Proponent
owns propriety technology for the recovery of lanthanides from the imported
lanthanide concentrate, and this will be employed in the plant. Lynas will also
employ state of the art solvent extraction equipment and process technologies for
the purification and separation of the elements. These technologies enable the
production of high purity lanthanide products for the manufacture of magnets and
batteries, polishing powders, catalysts, and glass, etc. The transfer of technology
will take place at the point when employees are sent for training in Australia or
overseas and also, by way of regular visits by foreign technical specialists who
will be sent to Malaysia to provide onsite job training to the local staff based at
the plant in Kuantan. The Project Proponent is currently in talks with the State
Government of Pahang to collaborate with the University Pahang Malaysia on
Research & Development. This will also create trained, professional workforce.
In addition, the transfer of technology will also take place domestically with staff
learning the skills while on the job.

Growth of Other Supporting Industries and Surrounding Areas: The
proposed plant in Malaysia is expected to create new business opportunities for
the following industrial sectors:

Gas and petroleum;
Chemical reagents;
Water;
Transport/logistics;
Insurance; and
Banking.

Additionally, the plant is expected to complement the Governments efforts in
attracting the establishment and relocation of the following industries in Malaysia
with the availability of lanthanide products within Malaysia, i.e. through import
substitutions:

Hybrid vehicles
Neo magnets
Flat panel displays
Ceramic capacitors
NiMH batteries
Fuel cells
Phosphors
Polishing powders

5-93

The setting up of the proposed plant within the GIE in Kuantan is also expected to
promote the development of new, technologically advanced industries including
small and medium size industries (SMIs) that use lanthanide products as raw
materials/components, that are geared towards meeting the demands of relevant
globally competitive industries.

Increased Employment Opportunities: The plant is expected to employ 398
local Malaysian and 20 expatriate employees in the 1
st
year of operations. The
expatriate employees will train locals until such time the locals attain sufficient
skills and technical knowledge to subsequently take over the responsibilities from
the expatriates. Additionally, further job opportunities will become available for
Malaysians not only in the this industry but also, job opportunities for the
manufacturing sector in the Eastern Corridor on the whole as a result of the spin-
off effects to related supporting industries and sectors such as chemical, gas and
petroleum, chemical reagents, water, transport/logistics, insurance, banking
sectors, etc.

Economic Benefits: The proposed Advanced Materials Plant in Malaysia is
expected to bring about positive multiplier effects to the Malaysian economy.
Based on a multiplier effect factor of 2 (i.e. 2 x multiplier effect of business
expenditure and project operating costs), the total direct and indirect contributions
to the Malaysian economy over the first 15 years of operations (year 2008 2022)
by the proposed plant is expected to be significant. In addition, Lynas proposed
operations in Malaysia are projected to generate significant tax revenue for the
Malaysian Government over its first 15 years of operations (year 2008 2022).

Business for Local Suppliers: Creation of demand for local supplies of relevant
raw materials and components such as chemical reagents (hydrochloric acid,
sulphuric acid, magnesium oxide, lime, etc.), gas, etc. which is expected to
encourage the shift towards the use of local contents by other relevant industries.

5.9 TRAFFIC AND TRANSPORTATION

At present, the proposed plant site is accessible from Kuantan-Kemaman (Federal
Route 3) Road and Gebeng Bypass Road. Jalan Kuantan-Kemaman is part of Federal
Routh 3 and is a two-lane road. From this road, there are three roads that connect to
the GIE. The Gebeng Bypass is a new road that bypasses the Kuantan Port.

5-94

In assessing traffic impacts, a Traffic Impact Assessment (TIA) was undertaken for
the Advanced Materials Plant in November 2007. The complete report is appended in
Appendix 4. However, the traffic volume assessed for the operational phase of the
TIA is based on higher vehicle numbers which were estimated in November 2007.
Since then, the traffic volume for the plant in its operational phase has been revisited
by the Project Proponent and new numbers have been generated. These vehicle
numbers are observed to be lower than the initial case. At the time of reporting, the
TIA was being updated and revised to reflect the impact arising from the new data set
and thus was not ready for inclusion in this report. However, since the conclusions
and recommendations of the assessment of the original report remain the same, these
are summarised below.


In the earthworks phase, heavy earthmoving plant such as bulldozers, excavators and
compactors would be transported to the site via low loaders. Low loaders by virtue of
their size occupy most of the carriageway and are generally slower in speed. These
factors combined will cause inconvenience to other commuters and also pose a safety
risk.

Construction activities will comprise civil works, mechanical and electrical services,
and support services. The initial construction activities will therefore require the
delivery to site by road of construction materials such as concrete and structural steel.
As construction continues, the proposed plant components and associated
infrastructure items will be brought to site. In addition, smaller machinery and
materials such as some mechanical equipment, pipework, valves, electrical cabling
and wiring, and instrumentation will be delivered by light vehicles. The majority of
construction material deliveries during initial construction will be by standard low
loaders, trailers and trucks.

Off-site transport of construction spoil/debris will also be carried out. Similarly, this
will result in increased traffic movement. Prolonged and repeated overloading by
heavy vehicles would also potentially affect road surfaces causing breakages and
potholes which will further inconvenience road users.

The estimated number of truck movements generated during the peak construction
phase was not available at the time of reporting. However, the majority of these trips
will be from the construction materials suppliers in Kuantan and Kemaman. In
addition, in the event the construction workers are provided accommodation off-site,
they will generate a combination of car, van and motorcycle traffic on the road. This
traffic will peak at each change of shift for the workforce.

5-95

Based on the TIA, the predicted volume of construction traffic is expected to be less
than 100 vehicles per hour. Considering the low volume of construction traffic, it is
not likely to cause significant impact on the performance of the surrounding road
network. However, it is recommended that the vehicles use the Gebeng Bypass and
enter the proposed plant site through the 2-lane road located to the west of the site.
This is in view of the low volume traffic on the roads.

Impacts arising from increased traffic to and from the plant site during the
construction phase will be minimised by observing the following:

Transportation of construction machinery and materials will be carried out only
during off-peak hours of the day. Off-site transportation of waste material will be
regulated to avoid peak traffic periods (6.30 - 8.30 am and 4.30 - 6.30 pm);

Speed of vehicles will be restricted to 90 km/hr to reduce the impacts of dust
dispersion and material spillage;

Safety measures with regard to loading and transporting of heavy machinery
construction materials, raw material cargo and finished products will be observed
at all times. All loads will be secured with chains or strong rope. Dusty material
will be secured with tarpaulin covers.

The transportation vehicles used will be well maintained and, the drivers licensed
and competent. This is to prevent any undue incidents as there are residential areas
located along the transportation route.

b. Operational Phase

Increased traffic will also be generated from the movement of in-coming raw material
supply vehicles and out-going transportation vehicles carrying the product from the
plant. The results of the traffic analysis indicate that the increase will not be
significant.

As the lanthanide concentrate is classified as a radioactive raw material in accordance
with the Atomic Energy Licensing Act, 1984, a transportation licence is required from
the AELB to transport the concentrate from the Port of Kuantan to the plant site. The
Project Proponent will apply for this licence once the Class A Milling Licence has
been issued for the operational phase. The transport licence will state the
transportation requirements and conditions, and the Project Proponent is committed to
ensuring compliance to these requirements.

For trucks/tankers that would be involved in the transportation of chemicals
(including concentrated acids, corrosive substances), finished products and raw
material (lanthanide concentrate) during the operational phase, the following
measures are necessary:

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The use specially designed trucks dedicated for the transport of chemicals;

The use of adequate warning and information signs and safety equipment on all
trucks/tankers;

The use of major highway routes and avoiding smaller roads which pass through
community areas;

The strict adherence to the relevant regulations pertaining to road transport;

Provision of proper training to plant technicians involved on loading and
unloading operations at the plant area;

Equipping the trucks/tankers with the appropriate safety equipment, both
personal (protective clothing) and emergency equipment (radios, spill
containment kits, etc.);

Designing the facilities on the tankers to minimise the likelihood of spillages
occurring due to overspilling and incorrect positioning of the vehicles;

Where possible, to select transport routes that avoid built-up or congested areas
as much as possible;

Proper scheduling of the lanthanide concentrate transportation trucks should be
carried out to ensure the truck turn-around time is not delayed and to prevent
truck-waiting within the site which will lead to a line-up of trucks along the
Kuantan-Kemaman Road and the Gebeng Bypass. This would pose a safety
hazard in addition to obstructing the smooth flow of traffic along the public road.


6-1
CHAPTER SIX
6.0 ENVIRONMENTAL MANAGEMENT PLAN

6.1 PROJECT OVERVIEW

This section presents the environmental management requirements for the construction
and operational phases of the proposed Advanced Materials Plant. Effective management
and monitoring of activities on the site will be essential to ensure environmental
objectives are met and operations are carried out in an environmentally sustainable
manner.

In Chapter Five of this report, the potential environmental impacts have been assessed
and suitable mitigation measures recommended tominimise these impacts to meet
regulatory limits and comply with best industrial environmental management practices.
The mechanisms for ensuring that these mitigation measures are implemented, and are
effective, are recommended in this chapter. The base document for the environmental
management of the project is called the Environmental Management Plan (EMP).

Separate EMPs will be developed for the construction and operational phases of the plant
to describe how the recommendations of this preliminary EIA, and any further conditions
imposed by DOE Pahang would be implemented by the nominated EPCM Contractor
and Lynas during the construction and operational phase respectively.

As per the requirements of DOE, the construction phase EMP will be developed and
approved by the department prior to the commencement of construction works and
likewise the operational phase EMP prepared and approved before the start of the plant
operations.

6.2 EMP FORMAT

The EMP will be developed in accordance to the latest guidelines prepared by DOE. A
typical format of the document and the key information to be included in each of the
chapters are presented below:

Chapter 1: Introduction: States the objectives of the EMP, the scope of the EMP, a
statement of key environmental issues identified in the establishment of the plant within
the Gebeng Industrial Estate (GIE) and details of the environmental management
requirements stipulated by DOE as part of the conditions of approval for the project.

Chapter 2: Policy: Provides an outline of the companys objectives in protecting the
environment, its environmental policy; and long term commitment in practising
sustainable development.

6-2

Chapter Three: Organisation Chart/Budget: Provides details of top management
personnel responsible in managing environmental issues; details of the nominated
environmental consultants and laboratory employed for the environmental monitoring,
frequency and nature of training provided to the employees on safety and environmental
issues; and estimated budget for implementing the EMP. In addition, a statement on the
reporting procedures, complaint response procedures, and actions to be undertaken if
adverse monitoring results are reported will also be presented.

Chapter Four: Environmental Requirements: Describes the EIA approval conditions,
related standards and regulations stipulated under the Environmental Quality Act, 1974.

Chapter Five: Monitoring Programme: Details the requirements for baseline
environmental monitoring which will be carried out prior to project implementation; and
the proposed monitoring programme for both the construction and operational phases of
the project.

Chapter Six: Significant Impacts and Pollution Control Measures: Summarises the
significant impacts identified and the proposed pollution control or mitigation measures
to be implemented.

Chapter Seven: Environmental Contingency Plan: Outlines the requirements for
emergency procedures for unplanned incidences that may potentially result in adverse
environmental impacts such as hazardous spills, failure of pollution control equipment,
etc. A list of personnel involved and the relevant government agencies will also be
presented.

Chapter Eight: Summary: States the salient features of the various chapters within the
EMP document.

6.3 GUIDELINES FOR THE CONSTRUCTION PHASE EMP

The primary objective of the construction phase EMP will be to ensure that sound
environmental practices are adhered to during the construction phase. This will include
the recommendations presented in this report, DOEs EIA Approval Conditions, and
further requirements which become evident during the construction process itself.

The EMP will be prepared in accordance to the format outlined in Section 6.2 above. In
addition, the following management procedures are recommended:

The contract between the Project Proponent and the nominated EPCM Contractor
shall specify that the EPCM Contractor and their Subcontractors are required to
adhere to the environmental protection measures recommended in this PEIA, legal
provisions of the Environmental Quality Act, 1974 and all other requirements by
DOE which will be stated in the EIA Approval Conditions.

6-3

A designated site personnel, i.e. Site Manager/Engineer or Supervisor who has a
background in environmental management practices will be appointed to assume
responsibility for the execution of the requirements of the EMP throughout the
duration of the construction phase.

The findings of the environmental compliance audits (discussed under Section 6.7)
will form the basis of corrective actions to be resolved by the EPCM Contractor/Sub-
Contractor.

As the duration of the construction phase of the project is approximately 15 months, it
will not be necessary to review the EMP after the first year of construction. However, in
the event unanticipated incidences which result in adverse impacts occur on site, the
EMP will be updated immediately to incorporate the particular scenario.

6.4 GUIDELINES FOR THE OPERATIONAL PHASE EMP

The format of the EMP developed for the operational phase of the project will be similar
to the format outlined under Section 6.2. Some of the additional information to be
incorporated in the EMP includes the following:

Development of a set of brief, written environmental management procedures for the
various activities in the operational phase. Management personnel and the employees
(operators) would be required to adhere to these practices as part of their job
function;

Selection of an Environmental Officer to ensure that the measures recommended in
the EMP and other specific written environmental procedures are adhered to. The
person shall possess the relevant experience in environmental management and
capable of handling emergency situations. The person should also be empowered
with sufficient authority to effect rapid action in the event of an emergency situation
where potential adverse impacts to the environmental are likely.

Easy access by employees to technical support and advice; and pollution control
equipment in the event problems arise;

Provision should be made for the management of unforeseen incidents or events via
an Emergency Response Plan. This would include ensuring that site personnel know
whom to contact for technical advice or equipment if there is an emergency; and

Training of plant operators in basic environmental management practices.

6-4

Assuming there are no changes in the plant operations, the EMP will be reviewed after
the first year of operation and every two years thereafter. However, if there are process
related or operational changes which require a change in environmental management
practices, the EMP document shall be revised accordingly before the change is effected.
Also, if any shortcomings in the document are identified based on the findings of the
periodical environmental audits, these sections will be revised/updated as necessary in
line with the companys corporate environmental management policies.

6.5 ENVIRONMENTAL MONITORING AND AUDITING

Environmental monitoring will be required for the following during both the construction
and operational phases of the project:

Sungai Balok river water quality and river bed sediment quality,
Boundary noise levels;
Ambient air quality;
Emissions arising from the waste gas treatment system; and
Soil and groundwater

These recommendations are based on the findings of this PEIA study and will be
incorporated within the EMP document. For the construction phase, the Consultants
recommend that these requirements be specified in the tender document for EPCM
Contractors (and their respective Sub-contractors). The data collected from these
monitoring events shall be submitted to DOE Pahang. Monitoring events undertaken for
submission to DOE shall be carried out by analytical laboratories which are certified by
the Department of Standards of Malaysia.

Scheduled environmental audits shall also be undertaken as specified by DOE Pahang in
the EIA Approval Conditions.

The objectives of the environmental monitoring programme are:

To develop a database to facilitate the identification of any short or long term
environmental impacts arising from the construction and operation of the plant;

To provide an early indication if any of the environmental control measures or
practices are failing to achieve the acceptable standards; and

To provide environmental quality data to support the findings of the compliance
audit during both the construction and operational phases of the project.

6-5

6.5.1 Baseline Data

The baseline environmental quality data presented in Chapter Four of this report
provides a general indication of the baseline environmental conditions at the time of
reporting. Environmental data at the site boundary were collected during a monitoring
event undertaken in October 2007. This information was used as a basis for both
qualitative and quantitative impact assessment in this EIA.

Since the Project Proponent intends to commence construction activities in March 2008,
a second monitoring event for the collection of baseline environmental quality data is not
required as the proposed site is a cleared site with no on-going activities. The data
obtained thus far is deemed sufficient to represent the plant sites baseline conditions
unless there is a specific requirement from the DOE in the EIA Approval Conditions to
re-assess the baseline environmental quality shortly before the onset of construction
activities.

The results obtained from the monitoring programme carried out during the construction
and operational phases will be compared against these baseline conditions, and the
findings used to indicate if the project implementation activities have attributed to the
change in the environment; and to assess the effectiveness of the mitigation measures.

6.5.2 Water Quality Monitoring

6.5.2.1 Construction Phase

In the construction phase, the main concern will be increased sediment loading into
Sungai Balok as a result of soil displacement from the site due to construction activities.
The loading is not expected to be significant as the activities will be largely confined to
the areas where structures are proposed. Additionally, the topography of the site is
generally flat and cut and fill activities will be limited to areas the built-up areas.

One silt trap has been proposed in the south western corner of the site which will cater
for all construction runoff within the construction area. The silt trap details are discussed
in Section 5.2.2 in Chapter Five of this report.

To ensure the efficiency of the silt trap in the removal of soil particles and oil and grease,
the monitoring of the overflow from the silt trap at its outlet is required for both these
pollutants. The overflow from the silt trap shall comply with the 50 mg/l limit and will
not contain any traces of Oil & grease. The silt trap will be maintained by regular
desilting by the Contractor.

6-6

Additionally, river water samples will be collected from Sungai Balok at seven stations
(W1-W7) along its 15 km stretch (commencing from the river mouth to a location
slightly upstream of the site) using the grab sampling technique. The details of these
locations are presented in Section 4.6.4 within Chapter Four of the report. The station
locations are marked in Exhibit 4.14.

As the Sungai Balok river has tidal influence, samples will be collected during high and
low tides. At each location, three (3) samples will be collected (at the surface, mid-depth
and above the seabed) and mixed in a single container, and one sample drawn out to
represent a composite sample for laboratory analysis.

For the construction phase, it will suffice to monitor only the following parameters: TSS,
Oil and Grease, DO, BOD, COD, pH and temperature. It is recommended that samples
be taken once a month for the first six months of the construction phase when the
activities onsite will be the most intensive. Subsequently, the monitoring can be
staggered to once every quarter until the completion of the construction phase. This
recommendation will require confirmation from DOE Pahang.

6.5.2.2 Operational Phase

In the operational phase, the treated effluent from the Wastewater Treatment Plant
(WWTP) will be discharged directly into Sungai Balok via the site stormwater detention
pond and an earth drain which will run west from the site to the river for a distance of
about 3 km.

To ensure the treated effluent leaving the site complies with the parameter limits of
Standard B of the Environmental Quality (Sewage and Industrial Effluents) Regulations,
1979 the discharge from the treated water storage pond will be monitored on a continual
basis for flowrate, pH, temperature and suspended solids. Samples will be collected
periodically for laboratory analysis of the 23 parameters of the Standard B. For quick
turnaround, the use of COD & BOD kits may be considered. Discharge of treated
effluent into Sungai Balok will immediately be discontinued if the samples do not
comply with the stipulated limits.

The stormwater detention pond will be provided with automatic level control to
maximise the volume available within the pond for containment of rainwater or spills.
The pond will be inspected on a daily basis to ensure that the equipment is operating
effectively and to determine if any incidental spills have reached the pond.

To assess the impact of the treated effluent discharge on the receiving waterbody, Sungai
Balok, water samples will be collected from seven locations within the river body. These
sampling locations are similar to the locations recommended for the construction phase
which are marked in Exhibit 4.14. The parameters to be monitored shall be similar to the
parameters monitored for the baseline river water quality monitoring events carried out
as part of the EIA study (Table 4.14 in Chapter Four of this report). The details of the
monitoring programme will require confirmation from DOE Pahang.

6-7

6.5.3 Boundary Noise Monitoring


Boundary noise levels will be recorded at four (4) monitoring stations (N1, N2, N3 &
N4) which represent the prevailing noise levels along the site boundaries (four corners of
the site).

The details of these monitoring locations and the parameters monitored are described in
Section 4.6.1 in Chapter Four of this report.

As the site is located within the Gebeng Industrial Estate (GIE), the surrounding
receptors are generally industrial facilities. The nearest human settlements to the project
site are Kampung Sg. Ular, Kampung Gebeng and the Tanah Kemajuan Gebeng which
are located 3 km to the east-northeast of the site. Thus, noise monitoring at these
receivers is not required.

The location of these monitoring stations is presented in Exhibit 4.14.

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 LA
eq
, LA
max
, L
A5
, L
A10
,
L
A50
, &L
A90
& L
A95
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. This monitoring
frequency will require confirmation from DOE Pahang.


The noise monitoring programme recommended for the operational phase of the plant is
similar to the construction phase programme with regards to the numbers and location of
the monitoring stations. It is recommended that noise monitoring be undertaken once
every quarter subject to confirmation from DOE Pahang.


6-8

6.6 AIR QUALITY MONITORING


Ambient air quality will be monitored at four (4) monitoring stations (A1, A2, A3 & A4)
which represent the ambient air quality along the site boundaries (four corners of the
site).

The details of these monitoring locations and the parameters monitored are described in
Section 4.6.2 in Chapter Four of this report.

As the site is located within the GIE, the surrounding receptors are generally industrial
facilities. The nearest human settlements to the project site are Kampung Sg. Ular,
Kampung Gebeng and the Tanah Kemajuan Gebeng which are located 3 km to the east-
northeast of the site. Thus, air monitoring at these receivers is not required.

The air samples collected will be analysed for Total Suspended Particulates (TSP),
Particulate Matter (PM
10
2
) and nitrogen dioxide (NO
2
) which are
the primary ambient air quality pollution indicators.

The results of the monitoring exercise will be used to ascertain if the dust suppression
measures implemented for potentially dusty construction activities; and vehicle
movement are effective. The monitoring exercise will also ensure regular maintenance of
construction vehicles and equipment and prevent excessive noxious exhaust emissions.


During the operational phase of the plant, the emissions arising from the waste gas
scrubber system will require periodical monitoring to ensure compliance to the
Environmental Quality (Clean Air) Regulations, 1978.

It is recommended that the stack emissions from the waste gas treatment system be
monitored every month for the first two years of the operational life of the plant and once
every quarter thereafter and the results submitted to DOE Pahang. Unless the monitoring
data show inconsistencies in the performance of the waste gas scrubber system, the
quarterly monitoring programme recommended should suffice. However, in the event,
the results show signification fluctuations, the monthly frequency will be maintained
until such time the readings are generally constant. The parameters to be monitored
include sulphuric acid mist or sulphur trioxide or both, hydrofluoric acid and Total
Suspended Particulates (TSP) and the limits shall comply with Standard C of the
Regulations. The final parameters will be set by DOE Pahang.


6-9

Ambient air quality at the site boundaries will need to be identified. The location of the
stations and the parameters to be monitored are similar to those recommended for the
construction phase. It is recommended that ambient air monitoring be undertaken once
every quarter subject to confirmation from DOE Pahang.

6.6.3 Soil and Groundwater Monitoring


No soil or groundwater quality monitoring is necessary during the construction 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
(7) 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, TPH (USEPA Method 8015/8260);
Volatile Organic Compounds, VOCs (USEPA 8260);
Semi-Volatile Organic Compounds, SVOCs (USEPA 8270);
Anions (Chloride and Sulphate); and
13 Pollutant Metals i.e. antimony, arsenic, beryllium, cadmium, chromium, copper,
lead, mercury, nickel, selenium, silver, thallium and zinc (USEPA 6010/6020 for all
& 7471 for mercury).


6-10

6.7 ENVIRONMENTAL COMPLIANCE AUDITING

Environmental compliance auditing will be carried out to spot check for compliance
with the EMP, i.e. to ensure that the environmental management procedures,
recommended mitigation measures and monitoring programmes are implemented at the
site. The EMP developed will include a checklist (for the construction and operational
phases) which will be used by the Auditor during the compliance audit. The audit will
also include a review of the relevant permits and licences required by the DOE,
environmental monitoring data, review of complaints received from the public (if any)
and other related issues as well as a thorough inspection of site activities.

The results of the audit will be used to identify any weaknesses in the EMP and to
provide information for updates where necessary.

It is recommended that quarterly audits are carried out during both the construction and
operational phases of the project.

The audit protocol shall include the following activities:

Review and verification of historical environmental quality data;
Identification of specific issues of non-compliance;
Recommendation of suitable mitigation measures to mitigate the non-compliance
observed; and
Assessment of the overall adequacy of the mitigation measures implemented and if
there are any short-comings, the auditor will recommend suitable modifications
which will be incorporated in the EMP.


7-1

CHAPTER SEVEN
7.0 EMERGENCY RESPONSE PLAN

7.1 INTRODUCTION

An Emergency Response Plan (ERP) is an essential component of a facilitys safety and
loss strategy and provides an organised structure for a chain of actions to be put into
motion in the event of an emergency on the site. An emergency, in the context of the
ERP, is defined as an incident which has the potential to cause injury or loss of life,
and/or damage to plant, property and the surrounding environment.

This section outlines the requirements for the preparation of an ERP. This general outline
of the plan is not intended to provide specific details on how to handle potential
emergency situations but for use as a template or guide in the development of a more
detailed site specific plan.

An ERP is required for the operational phase of the Advanced Materials Plant.

7.2 OBJECTIVES

The main objectives of developing the ERP for the Advanced Materials Plant operations
are to:

Establish a formalised emergency organisation structure and counter-procedures to
control and contain any emergency on site through prompt and effective response
measures so that its effect is localised;

Ensure that trapped or injured persons are rescued and given prompt and appropriate
medical assistance;

Control the spread of the damage arising from the emergency situation to the
environment including the nearest sensitive receptors;

Communicate information on the emergency to the relevant plant personnel and the
relevant offsite parties including the Royal Malaysian Police, Fire Fighting
Department (BOMBA), Department of Occupational Safety and Health (DOSH),
Department of Environment (DOE) and the Local Authority (Majlis Perbandaran
Kuantan);

Maintain information and records of investigation into the incidents/accidents;

7-2

Restore normality at the site prior to facility personnel re-entering the site after an
emergency and resuming work; and

Provide training for the site personnel in emergency response management to
maintain a high level of preparedness at all times.

7.3 BASIS OF EMERGENCY RESPONSE PLAN (ERP)

The ERP is a formal document that identifies the potential emergency conditions at the
plant and specifies pre-planned actions to be followed to minimise property damage and
loss of life. The document specifies the actions the plants management should undertake
to moderate or alleviate the impact from accidents and contains step-by-step procedures
and information to assist in issuing early warning and notification messages to
responsible emergency management authorities.

The effectiveness of the ERP can be enhanced by promoting a uniform format whereby
all aspects of emergency planning are covered in each plan. Uniform emergency action
plans and advanced coordination with local and federal emergency management officials
and organisations should facilitate a timely response to an emergency situation. An
emergency response plan generally contains the six main elements described below:

Identification of Possible Emergency Situations

The list of hazards resulting in activation of the ERP cascades down from the full
Hazard Identification exercise. From the exercise, the high and medium risk hazards
will be identified and the threats documented. The emergency response actions
relevant to each of these hazards will form the focus of the emergency planning
exercise.

Notification Flowchart

A notification flowchart indicates the nominated persons who are to be notified
during the emergency and in the order of priority. The information presented on the
flowchart is needed to ensure the timely notification of persons responsible for
handling the emergency situations.

Emergency Detection, Evaluation and Classification

Early detection and evaluation of the situation(s) triggering event(s) that initiates or
require an emergency action is crucial. The establishment of procedures for reliable
and timely classification of an emergency situation is necessary to ensure the
appropriate course of action is taken based on the urgency of the situation.

7-3

Responsibilities of Personnel in an Emergency

A clear definition of the responsibilities of personnel for ERP related tasks must be
determined during the formulation of the plan. Facility operators are responsible for
developing, maintaining, managing and implementing the ERP. Federal and local
emergency management officials have statutory obligations for warning and
evacuating affected areas. The ERP must clearly specify the responsibilities of
operators and when (and how) those responsibilities are transferred to government
officials, to ensure timely and effective action.

Emergency Preparedness

Actions of the ERP are taken to moderate or alleviate the effects of a potential
situation and, the facilitys responses to such situations.

Impact Zone Maps

Impact zone maps delineate the areas that could be affected as a result of accidental
events at the facility. Impact zone maps are used both by the facility operators and
emergency management officials to facilitate timely notification and evacuation of
areas affected by accidental events.

7.4 EMERGENCY RESPONSE PLAN (ERP)

7.4.1 Organisation

In the operational phase of the project, the plant management have to set-up a Health,
Safety and Environmental (HSE) committee to ensure all issues related to safety, health
and environment pertaining to the plant, employees and surrounding environment, are
adequately incorporated into the actual implementation of the ERP.

Upon agreement or acceptance of the proposed ERP by DOE, the HSE committee shall
ensure that all personnel are familiar with the plan. To ensure workability of the plan,
training session and regular rehearsals by means of drills have to be conducted.

7.5 LOCAL RESPONSE TEAMS

The Gebeng Industrial Area has a Local Response Team, i.e. Gebeng Emergency Mutual
Aid (GEMA) comprising the HSE committee members of the other industrial facilities
operating within the industrial area. The local team would also be made-up of
representatives from the relevant government agencies and local authorities such as the
local BOMBA, DOSH and DOE. It is recommended that representatives from the RE
Plant become members of this team.

7-4

7.6 TYPES OF EMERGENCY

An emergency is an unforeseen combination of circumstances that disrupts normal
operating conditions and poses a potential threat to human life, health and property or the
environment if not controlled, contained or eliminated immediately. A number of
potential emergency events likely to occur during the plant operation are provided
below:
Natural Hazards:

Floods during monsoon events
Landslide/ Subsidence

Internal Plant Hazards/ Threats:

Fire
equipment malfunction
spillages of unattended fuel (diesel)
spillages of corrosive concentrated acids
ignition of leaked flammables
fire in office building
Explosion
equipment malfunction,
ignition of leaked diesel fuel used for on-site vehicles,
Internal road vehicle accident
transport trucks carrying concentrate and/or chemicals overturn
spilling material onto the ground;
collision of vehicles moving within the site, etc.
Spillages/releases of flammable liquid or gases
fuel used for on-site vehicles and machinery hydraulic fuel
natural gas release due to leaks
Rescue of personnel
Pinned under vehicles involved in accidents
Involved in accidents within the operating areas of the plant, etc

External Hazards/ Threats:
Violent protest action
fuelled by political, business or environmental events or
circumstances
Bomb threats

7-5

7.6.1 Emergency Classification Levels

Emergencies are classified according to their severity and urgency. An emergency
classification system is one means of classifying emergency events according to the
different times at which they occur and to the varying levels of severity. The emergency
classification level for the types of emergencies described in the previous section can be
further divided into three (3) levels of response. This three-level system is proposed as a
general principle to activate the type of emergency response as follows:

Level 1 (Local Level)

This is an emergency situation where only the plants operation personnel would be
required to manage and control the emergency. Level 1 emergency would normally
call for the plants own resources and equipment for the response.

Level 2 (Area Level)

This is an emergency situation which requires action and management by the
combined efforts of the in-house response team and external assistance by the
neighbouring facilities response teams.

Level 3 (Divisional Level)

This is an emergency situation where a Level 2 emergency has escalated into an
uncontrolled situation and has resulted, or would further result in the loss of many
human lives, extensive property or environmental damage that has reached a scale
that is beyond the control and capabilities of all response teams combine. The
Evacuation Action Plan is then needed to be activated.

7.6.2 General Responsibilities of On Scene Commander (OSC) and Emergency
Response Teams

The purpose of having a dedicated emergency response team within the plant site is to
take immediate action to combat the emergency at local level (Level 1). In the event the
emergency escalates to Level 2 or 3, the emergency response team has to ensure proper
actions are taken to control the emergency while waiting for the arrival of external
assistance from BOMBA and other external aids.

The emergency response team is lead by an On Scene Commander (OSC). The OSC is
usually a general officer who has operational control of emergency response forces and
supervises all on-site operations at the scene of the accident. He is the responsible person
for all decisions relating to the management of the incident. As an OSC, he should be
well versed with the plants operation and must have in-depth knowledge on
occupational safety and health.

7-6

The general responsibilities of an OSC during an emergency are as follows:

To ensure all emergency response team members assemble at a pre-determined
location according to their respective responsibilities.

To assess information and situation and decide on the actions to be taken as outlined
in the response flowchart.

To approve changes to the response plan during the event if necessary.

To direct the orderly evacuation of personnel not involved in the emergency response
to a safe place.

To ensure that all personnel are accounted for and coordinate search and rescue if
necessary.

To make the decision on raising the raising the alarm for external assistance in the
event the emergency escalates from Level 1 to Level 2 or 3.

To coordinate between the team members and the sub-team members.

To coordinate efficient hand over of fire fighting, area containment or other
responsibilities upon the arrival of external assistances such as BOMBA.

To assist the external assistance team(s) to combat the emergency event as whenever
required.

To ensure that the incident is recorded and reported to the HSE committee and to the
necessary government agencies such as BOMBA DOSH, DOE, etc.

Emergency Response Team

A typical emergency team comprises of sub-teams that are represented by individuals
who are familiar with the respective area of responsibility. For example, the First Aid
Team member would comprise of individuals who have basic knowledge and training in
First Aid and CPR (An example is provided in Exhibit 7.1). Each of the team members
shall acknowledge his/her responsibilities as an emergency response member having
pertinent duties and responsibilities in the event of emergency situations. For each
designated position in the team, there should be at least one (1) name assigned and two
(2) others as standby.

7-7

The following sub-teams shall be established as part of the emergency response team.

Fire Fighting Team

The Fire Fighting Team members should comprise of employees that are familiar and
trained for fire fighting. Preferably, the team members should be experienced in
handling the fire fighting equipment.

Area Containment Team

The Area Containment Team shall comprise of designated employees that have
adequate knowledge in toxic and hazardous materials on-site. The main
responsibility of the team is to provide containment area for diesel spillage,
concentrated acids, release of other chemicals and in the event of overspill of
concentrate onto road or public areas.

Security Control Team

During an emergency event the Security Control Team will be responsible to
maintain order at the premise and ensuring security at all times. This is crucial as
there may be presence of outsiders in the site during the emergency event. Some of
the primary responsibilities of the Security Control Team include prevention of
unauthorised entry during the emergency, control of vehicle movement and provision
of access to external assistance team(s), take head counts and conduct search and
rescue if needed.

First Aid Team

The First Aid Team members shall comprise personnel with basic knowledge of First
Aid and CPR. In an emergency event, the First Aid Team will be required to provide
immediate first aid to injured persons while waiting for the arrival of
ambulance/paramedical staff.

Communication Team

The Communication Team assumes the role of team coordination and provides
instructions through the command of OSC. The main responsibility of the team is to
ensure the instructions are correctly and timely conveyed to the right parties during
an emergency. The team will record instruction conveyed out by OSC and received
from all parties.

7-8

Restoration/Remediation Team

The Restoration/Remediation Team is responsible for the recovery of any losses and
damages caused by the incident. After overcoming the emergency and the situation
has been secured, the team will investigate the cause of the incident and estimate the
damages and losses. It is also the teams duty to propose remedial steps to restore the
affected area (with the collaboration of government agencies if required) and propose
the mitigation measure to prevent future occurrence.

7.6.3 Emergency Equipment and Materials

An emergency response plan must be based on realistic assessment of the availability of
the emergency response facilities and equipment. To ensure that the Emergency
Response Team is able to control an emergency situation, the team has to be fully
equipped by proper facilities and dedicated equipment. It is the responsibility of the Plant
Manager with the assistance of HSE committee to ensure the availability and proper
working condition of the equipment. Some of the typical equipment and materials are as
listed below:

Fire Fighting Equipment and Materials

o Fire hydrants with dedicated Fire Water Pumps and Fire Water supply
o Fire extinguishers
o Hoses and nozzles
o Fire blankets
o Rope
o Respiratory protection equipment
o Aluminium ladders or mobile lift platforms
o Hydraulic metal cutting equipment

Communication Equipment and Materials

o Alarms such as bells, sirens, flashing, rotating lights, etc
o Smoke alarms
o Intercoms
o Walkie-talkies
o Hailers
o Dedicated emergency phone line
o Signboards indicating emergency gathering location

7-9

Other equipment and materials

o Absorbent materials and booms
o Protective apparel such as coveralls, gloves and boots
o Safety masks and goggles
o Gas detectors for detection of leak gases if required
o Torch lights
o Fully equipped First Aid supplies
o Stretchers

Some of the other general contact details and communication materials that should be
provided include the following:

Dedicated hotline that enables calls to off-site response authority
Mobile tele-communication equipment
Copy of latest Emergency Response Plan
Plant emergency plans/ flowcharts
Diagrams of the plant site which indicate the location of fire hydrants and fire
fighting facilities
Material Safety Data Sheets (MSDS) and Waste Cards for all hazardous materials
and wastes stored within the site
List of operating instructions for the usage of emergency equipment
Updated staff duty roster
Relevant standing instructions list
Emergency Response Team Organisation with the corresponding Duty Chart
Contact list consisting of names and telephone numbers of persons to call during
emergency
A full set of as-built facilities drawings (architectural, civil, structural, mechanical
and electrical drawings)
Safety Manuals

7.7 EMERGENCY RESPONSE FLOW CHART AND RESPONSE PROCEDURES FOR ON-SITE
EMERGENCIES

The purpose of the on-site emergency response flow chart is to provide instructions on
the various actions to be taken on a step-by-step basis during the emergency. An example
is provided in Exhibit 7.2. For the actual ERP, details such as actual actions to be taken
and the responsibilities of each team members has to be clearly defined in the flowchart
and included in the ERP.


8-1
CHAPTER EIGHT
8.0 SUMMARY AND CONCLUSION

8.1 INTRODUCTION

This EIA study has assessed the potential impacts to the environment arising from the
development of the proposed Advanced Materials Plant on Lots PT 8249 and PT 13637
within the Gebeng Industrial Estate (GIE), Kuantan, Pahang. Mitigation measures 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.

The following sections summarise the findings of the assessment.

8.2 WATER QUALITY


Sources of water quality impacts predicted during the construction phase include:

Construction runoff and drainage; and
Sewage from on-site worker camps (if the construction labour force is housed on-
site).

Based on the above, the site preparatory works are not expected to result in adverse
erosion potentials as the proposed site has been cleared and filled to platform level. The
impacts arising are transient in nature, occurring only during the site preparation stage of
the construction phase. With the implementation of effective mitigation measures, this
risk will be further reduced.

Control of the construction phase impacts can be effectively mitigated with the
development of an Erosion Control and Sedimentation (ECS) Plan. An ESC plan is a
document that explains and illustrates the measures to be taken to control erosion and
sedimentation during construction. Typically, an ESC includes the following:

Description of predominant soil types within the affected area;
Details of site topography including existing and proposed levels;
Design details and locations for structural controls;
Details of temporary and permanent stabilisation measures; and
Description of the sequence of construction.

8-2

The ESC plans ensure that provisions for control measures are incorporated into the site
planning stage of development and provide for the reduction of erosion and sediment
problems.

The effectiveness of the ESC plan can be evaluated during the implementation of the
Environmental Management Plan (EMP) which includes regular monitoring and audits.
Mitigation measures include:

The clearing of vegetation and undergrowths should only commence after the site
layout/design has been completed and the site is ready to be worked upon.

All temporary discharge points required in the earthworks will be located, designed
and constructed in a manner that will minimise the potential threat of downstream
flooding.

Any disturbed earth caused by construction activities or fill operations must be firmly
consolidated and compacted by earth moving vehicles and compactors to reduce the
rate of possible erosion and release of loose soil particles

Denuded stretches must be re-vegetated or sealed immediately after the construction
works.

Uncovered stockpiles of excavated material or topsoil and fill material are prone to
erosion and therefore must be protected. Small stockpiles can be covered with plastic
sheets and large stockpiles should be stabilised by erosion blankets and regularly
damped.

Stockpiles of construction aggregate, spoil and excavated soil should be located at
areas within the project site that do not permit direct run off into water courses and
are generally flat. On site storage of excessive quantities of such materials should be
avoided.

Sediment retention structures such as silt traps and settling basins of adequate sizes
should be provided at suitable locations prior to discharge into the receiving drainage
channels. One silt trap has been proposed at the south western corner of the site as
indicated in the site drainage plan presented in Exhibit 5.2.1. Details of the silt trap
design are presented in Exhibit 5.2.2. The location of the silt trap is tentative pending
approval from the Local Authority.

The proposed silt trap will be regularly maintained and desilted to provide maximum
silt removal efficiencies. Oil and grease removal facilities will also be provided to
ensure the overflow from the silt trap does not have traces of oil and grease. Weekly
inspection of silt trap will be carried out by the Contractor.

8-3

The contractor will ensure that site management is optimised and that any solid
materials, debris, litter or wastes are not indiscriminately dumped on site or disposed
of in the existing unlined drains in the vicinity of the site or on other undeveloped
sites within the GIE. Appropriate waste receptacles will be provided and periodic
removal of any accumulated waste from the site should be arranged.

Sewage effluent generated from the workers camps will be treated prior to
discharge. Portable integrated treatment units certified by the Department of
Sewerage Services are available which treat the effluent to meet the Standard B
limits.


In the operational phase of the project, the primary source of industrial wastewater is the
Cracking & Separation Plant. The wastewater generated from the plant will arise from
the upstream extraction, downstream extraction, and product finishing processes.

Other forms of wastewater and contaminated streams generated from the plant operations
include:

Supernatant liquors and surface runoff associated with the Residue Storage Facility
(RSF);
Waste gas treatment system blowdown;
Discharge of water (drain-off) from the cooling towers;
Boiler blowdown;
Contaminated stormwater collected from bunded areas within the plant, namely the
reagent storage tank bunded areas;
Floor cleaning waters; and
Sewage and domestic wastewaters.

Two treatment systems, i.e. the High Sludge System (HDS) and the WWTP (bio
treatment plant) have been proposed for the plant operations. The HDS system is
essentially a neutralisation pre-treatment process for the wastewaters from the Cracking
& Separation Plant. Details of the treatment process are discussed in Section 5.2.3.3.

All other process waste streams and contaminated streams will enter the WWTP directly
without any pre-treatment. Sewage and sanitary wastewaters will be routed to a Sewage
Treatment Plant and the treated discharge will pumped into the WWTP. The wastewater
block flow diagram presented in Exhibit 5.2.4 (Chapter Five) identifies the major
sources of waste streams and their inflow into the HDS and the WWTP.

The final treated effluent will be held in clear wells and then pumped into the stormwater
detention pond (at an average rate of 500 m
3
/hr) and the combined discharge will be
released into the earth drain (external to the sites southern boundary) which flows into
Sungai Balok.

8-4

The untreated waste streams entering the HDS process and WWTP identified in the
section above will contain the following chemical species:

Suspended solids (SS)
NH3-N
Phosphate
Cations: Low concentrations of Cu, Zn, Mn, Cl, Hg, As, Pb, Cr, Th, Mg, Sr, U,
Ca, Al, Si, K, Ba, Fe, Na, K+Na
Calcium sulphate (CaSO
4
)
Magnesium sulphate (MgSO
4
)

If untreated, these waste streams will impact the Sungai Balok river quality in terms of
physical, biological and chemical impacts similar to those discussed under Section
5.2.2.2. To mitigate these affects, these waste streams will be subjected to treatment
within the HDS and the WWTP prior to discharge.

The impacts of discharging the treated effluent from the plant during the operational
phase have been assessed quantitatively to simulate the pollution loading to Sungai
Balok and predict the changes in water quality of the river with the added discharge of
the effluent from the Advanced Materials Plant.

The main conclusions of the quantitative assessment are summarised below:

Discharge rate of the WWTP treated effluent is very low compared to likely storm
water and river flow rates;

The impact of treated effluent alone on river quality is very low, and is likely to be
diluted by a factor of 150 by the river water.

The contribution of storm water runoff from the site to river impact could be more
significant than from the plant effluent.

Discharging untreated effluent to the river will reduce the river water quality. The
COD concentration could be increased by up to 30% but this impact is expected to
be only short term. It should also be noted that existing COD in the river system is
greater than 50mg/l as per Class III water quality standard. If there is a desire to
improve the water quality of Sungai Balok further then there needs to be
consideration of all discharges into the river system rather than considering only one
point source such as the Advanced Materials Plant.

The conclusions drawn from the analysis are subject to the following limitations

Sg Balok river flows are unknown;
Other pollution loading into external earth stormwater drain is not quantified;
and
Uncertainty in EMC values.

8-5
8.3 SOIL AND GROUNDWATER


Impacts on soil and groundwater quality during the construction phase are commonly
attributed to improper management and handling of hazardous materials stored at the
site. Potential sources of soil and groundwater quality impacts include:

Accidental spillage and leakage arising from the handling and storage of hazardous
materials/chemicals in diesel skid tanks, chemical/fuel dispensers and storage drums,
jerry cans or carboys that contain lube oil, hydraulic oil, paints and organic solvents
and other chemicals used during the construction phase;

Leakage arising from vehicle engine oil change, equipment and machinery, as well
as refueling activities;

Inappropriate hazardous waste storage and disposal practices;

Improper discharge of untreated sewage; and

Groundwater dewatering activity.

Soil and groundwater impacts arising from accidental spillage and leakage of hazardous
chemicals and wastes during the construction phase are assessed to be low due to the
limited quantities of chemicals used at any one time on-site during construction. In
addition, the extent of soil and groundwater contamination is likely to be localized and
surficial. These impacts can be readily addressed by implementing appropriate mitigation
measures discussed in the proceeding section.

Groundwater pumping may be required where foundation excavations extend below
static water levels. Such dewatering may be required for some refinery foundations.
However, the need for significant groundwater discharge is unlikely. In the unlikely
event that some dewatering is required, the extracted water will be conveyed via the silt
trap proposed for the construction works area prior to discharge into the sites drainage
system.

The risks of soil and groundwater contamination during the construction phase will be
appropriately managed and controlled by the following:

A secured area (enclosed with hardstanding imprevious base) will be provided for
the storage of any hazardous materials (including hazardous wastes);

All temporary fuel tanks and drum storage areas will be provided with drip collection
devices and be sited on sealed areas (for example, concrete paved areas) with
appropriate bunding for accidental spill containment. A valve should be installed at
the discharge outlet of the bunded area;

8-6

All activities that may result in the potential release of hazardous materials to the
ground such as changing of engine oils and lubrication oils from construction
vehicles, equipment and generators on site will be performed only on designated
sealed areas or on drip trays to reduce the risk of direct spill into the underlying soil
and groundwater. Spent oil must be handled and disposed of as scheduled waste;

Any accidental spills of fuel, oil or other hazardous chemicals will be cleaned up
immediately. The recovered media (contaminated soil, absorbent pads, rags etc)
should be disposed of as scheduled waste; and

Appropriate sanitary facilities will be provided and properly maintained for
construction workers throughout the construction stage. Direct discharge of untreated
sewage into underlying soil, groundwater or surface water is prohibited. If portable
toilets are procured to the site, they must be of sufficient numbers and meet the
requirements of Department of Sewerage Services, Ministry of Housing and Local
Government.


The areas of concern for the potential soil and groundwater contamination during the
operational phase include:

Lanthanide Concentrate Storage Shed;
Residue Storage Facility (RSF);
WLP Retention Pond;
NUF and FGD Retention Pond;
Acid storage area (tank farm);
Chemical Store;
The 10,000-litre aboveground diesel storage tank;
The emergency firewater pumphouse (with 1,000-litre diesel storage tank);
Diesel generators (with 5,000 litre diesel storage tank each); and
Scheduled wastes (waste oil, expired chemicals, etc) storage area.

In addition, other potential sources of impact include the periodic handling and
dispensing of chemicals with the process areas, spills of fuels and lubricating oils, albeit
in small quantities, may lead to minor spills and leakages. Such accidental releases are
usually a result of poor chemical handling practices and may likely occur at the
maintenance workshop and hazardous substances handling and storage areas.

Impacts to soil and groundwater resources associated with plant operations could be
easily addressed, prevented and overcome by implementing appropriate mitigation
measures discussed in the following subsection.
Prevention and control measures include the following:


8-7
The diesel fuel storage tank and reagent storage tanks will be located within
concrete-bunded enclosures capable of containing 110% of the contents of the tank
within each enclosure. The floor of the bunded enclosures will be concrete-lined with
an impermeable liner to prevent contaminant from permeating into the ground;

Appropriate instrumentation and control/trigger alarm to warn of possible overfilling
and to provide an alert mechanism in the event of significant fuel/chemical loss
should be provided for the storage tanks;

Operational control which includes regular/routine surveys, inspection and
maintenance of the diesel fuel tank, chemical tanks and their ancillary facilities
(pumps, valves and pipes) will be integrated into the plants environmental
management practices so as to identify and rectify any significant product losses or
ongoing spills/leakages which may be occurring;

Areas where regular or periodic handling and dispensing of liquid chemicals are
undertaken, such as maintenance workshop and hazardous waste storage areas,
should be concrete-paved with appropriate secondary containment (drip trays and
bunded areas) provided.

Any accidental spills will be assessed on a case by case basis and remedied,
including excavation and disposal of any contaminated soil (classified as scheduled
wastes) at a secure disposal facility.
Procedures and work instructions on proper chemical handling should be effectively
communicated to all operations and maintenance personnel;

Hazardous materials and waste storage, handling and disposal procedures will be
developed; and

Corrosion protection for steel tanks and their ancillary facilities (pumps, valves and
pipes) will be provided to prevent leaks.
In addition, groundwater should be monitored on a regular basis during the lifetime of
the plant operation. If contaminants are present at concentrations above the groundwater
quality screening levels such as the Dutch Intervention Values (DIVs), further
assessments will be necessary to determine the nature and extent of the contamination, as
well as to remove the potential source(s) of contamination.


8-8

8.4 NOISE


Major noise sources during the construction phase of the project include:


Building construction activities including piling; and

Transportation of construction equipment and materials: Vehicular noise will be
generated from the ingress/egress of trucks carrying materials to/from the site.

Kemajuan Gebeng (2.5 km southwest). The noise impacts arising from the plant will not
impact the noise environment at these receivers.

Based on the assessment of construction noise, the impacts during predicted are short-
term, transient and localised to the site and its immediate surrounding (within the buffer
zone of the industrial area).

The following standard noise control practices and measures will be implemented during
the construction phase:

Machinery and construction vehicles that may be in intermittent use will be shut
down between work periods or will be throttled down to a minimum;

The impact of piling noise can be minimised by the selection of quieter pile drivers
such as hydraulic pile, or bored piles.

Material stockpiles and other structures will be effectively utilised, where practicable,
to act as a screen for noisy equipment operating within the construction works area.

Noisy equipment, such as generators, will be checked for proper installation of
engine silencers to reduce emitted noise. Other machinery with high noise level
should be operated within enclosures.

All transport vehicles must comply with the noise requirements made under the
Environmental Quality (Motor Vehicle Noise) Regulations 1987. The maximum
sound level permitted for trucks used in the transport of goods or materials should
not exceed 88 dBA. Moreover, transportation vehicles should not be overloaded to
avoid driving with full engine capacity which results in higher noise being emitted.


8-9
In terms of workers safety and health, workers spending long hours on site, operating
machinery and equipment that generate loud noise, will be provided with protective
ear mufflers to prevent hearing impairment/loss.


The primary dominant noise sources during the operational phase of the plant include the
following: (the respective noise levels, when measured at one metre from the plant, is
also specified):

Rotary Kiln 97 dB(A)
Cooling Tower 99 dB(A)
Kiln Blower 97 dB(A)
Covered Conveyor 70 dB(A)
Conveyor Drive 97 dB(A)
Exhaust Fans 96 dB(A)
Compressor House 85 dB(A)
Pumps 98 dB(A)
Front-end Loaders 100 dB(A) (or 86 dB(A) at 5 metres)

The future noise levels at the plant site boundary were quantitatively predicted with the
use of a well established computer modelling programme SoundPlan 6.2 (developed by
Braunstein + Berndt, GmbH and accepted for use by the regulatory authorities in
Australia).

A single scenario was modelled which represents the combined noise levels from the
operation of the plant and the movement of trucks transporting raw material (lanthanide
concentrate), reagents and finished products.

The predictions are based on two assumptions:

Worst-case environmental conditions when the prevailing wind blows 100% of the
time in the direction of the receiver, i.e. in a north-easterly-easterly direction.

All equipment and machinery within the plant are operating simultaneously.

Truck movements consisting of 68 trucks per day for the reagents and 18 trucks per
day for the concentrate;
Trucks operating 24 hours per day; and

8-10
Speed on site is 30 km/h.
As the plant is to operate continuously, the night-time (10.00 pm - 7.00 am) noise level
criteria is the most critical and as such, the results are calculated as L
Aeq (9 hour)
dB levels.

From the results obtained, the highest predicted noise level from the operation is
received on the northern boundary of the proposed site. This level, which includes truck
noise, is L
Aeq (9 hour)
62 dB. The predicted noise level is dominated by the front-end
loaders moving between the Tertiary Leaching Plant and the Residue Storage Facilities.

Kemajuan Gebeng (2.5 km southwest). The predicted noise levels are these locations are
calculated to be below L
Aeq
35 dB and therefore not considered to be of significance.

When compared to the Department of Environment Malaysias The Planning Guidelines
for Environmental Noise Limits and Control, it can bee seen that the night-time level at
the northern boundary marginally (2 dB) exceeds the night-time criterion of L
Aeq (9 hour)

60 dB. However, these predictions assume that all four front-end loaders will be
operating continually and simultaneously for the entire night-time period, which may not
be the case in reality. Should the operation be intermittent, the L
Aeq (9 hour)
level would be
lower and may then comply.

It is therefore recommended that once the plant is operational, a noise survey be
undertaken on the boundary of the site. Should it be found that the front-end loaders or
other plant is causing the noise levels to exceed the criterion, noise control can be
undertaken to ensure compliance. For the front-end loaders, suitable noise control can
include upgrading the engine covers and exhaust system.

The impact from trucks on public roads is considered to be minimal considering the low
truck volumes (86 trucks per day) and the existing traffic volumes. Also, as the trucks
are likely to be taking different routes to the site, unlike the scenario of trucking
campaigns from a port to a particular site, there is not a concentration of noise at specific
locations.

Assuming the plant specifications and expected truck movements used in the model, the
results clearly indicate that during both normal operation and with the additional

noise associated with transportation of the lanthanide concentrate from the port, the
operation of the plant complies with the Department of Environment Malaysias The
Planning Guidelines for Environmental Noise Limits and Control at all times.

However, to further reduce the plant operating noise and as best industrial practice, the
following measures will be implemented:

When selecting the equipment models for the plant from the various vendors, the
noise attenuation features of the equipment will be given due consideration. In
general, the newer equipment models tend to have more effective noise attenuation

8-11
features. Where practical and cost effective, these equipment should be given
priority. It is recommended that performance guarantee or contract specifications
stipulate a requirement limiting the noise level of the equipment to a maximum of 85
dB(A) at 1m where practical.

For additional noise attenuation, engineering measures such as installing mufflers,
enclosures, barriers, lagging, noise-absorptive materials and silencers may be
employed where practical.

Where practical and feasible, noisy equipment should be housed within a building or
an enclosure. The enclosures may range from a complete fully accessible room with
proper air ventilation system to a structure which has side claddings that act as noise
barrier.

Insulation of equipment piping accord further noise reduction.

The orientation of the equipment within the plant area will be such, so as to capitalise
on the existing buildings and structures as noise barriers. Barrier shielding in many
instances has been observed to significantly attenuate noise levels. For example, an
intervening building between source and receiver may reduce the noise level by
about 5 dBA.

The layout of noisy equipment within the plant will be aligned in a manner such that
the distance of the equipment from the boundary is maximized, at least 25 metres
from the nearest neighbouring site boundary.

Noise emitted by the compressors, fans and pumps can be further controlled by
reducing the vibration level of the machinery and their ancillaries.

For the control of occupational noise, workers operating within noisy areas of the plant
will be provided with ear plugs or ear muffs. In high noise level environments within the
plant, it is advisable to wear both types in combination. The noise attenuation or
protection afforded by ear protectors varies with the frequency of the noise, providing
more protection at higher frequencies. At average frequencies of 500 Hz to 1000 Hz, ear
plugs alone provide protection of about 22 dB (A). Ear muffs are better, providing
attenuation of 30 dB(A) and in combination, the protection accorded is in the range of 34
dB(A).

8-12

8.5 WASTE


The types of solid wastes generated during the construction phase can be broadly
categorised based on their nature and ultimate disposal method into the following:

Municipal waste;
Scheduled waste (regulated hazardous wastes); and
Unregulated wastes.

Improper disposal of these wastes at unauthorised areas will contribute to unhealthy and
unattractive surroundings. Poor management of construction waste will result in the
creation of illegal dumping grounds in secluded areas at the nearby villages and
surrounding forested areas. These illegal dumps provide an ideal habitat for disease-
vectors such as mosquitoes, flies and rats which potentially cause health impacts to
nearby settlements. In addition improper disposal of hazardous waste will result in
contamination of the soil and potentially groundwater. They also pose fire hazards during
the dry seasons, clog the local drainage system and caused localised ponding and even
flooding of nearby streams and river systems during the monsoon season. The dumps are
also sources of adverse negative odour impacts.

The implementation of proper waste management practices within the site will minimise
the impacts arising from the above waste sources. Mitigation measures recommended
include:

The potential environmental impacts arising from the improper management of
municipal wastes can be minimised with the implementation of the following practices:

Good housekeeping practices are essential within the site and especially critical at
the workers camp (if set-up within the site premises).

General construction spoil should be recycled on site as much as possible. For
example, construction aggregate materials, cement and rock are readily used on site
where possible as backfill material for low lying areas.

Domestic waste generated from the workers camps should be stored in garbage
bins/secure containers and be collected regularly by a licensed contractor for disposal
at an approved landfill.

Unsalvageable construction spoil should be stockpiled at a designated site and sold
to salvage yard operators or other contractors interested in recycling the material.
Alternatively, disposal arrangements can be made with registered private contractors

8-13
or Majlis Perbandaran Kuantanto carry out regular collection and off site disposal at
the approved disposal site.
Types of scheduled wastes potentially generated during the construction phase will
require proper handling, storage and disposal in compliance to the scheduled waste
regulations. The copies of the waste consignment notes will be filed by the Contractor
for record.

The construction works Contractor shall ensure that only licensed scheduled waste
contractors are employed for the transportation of these scheduled wastes to the
scheduled waste disposal facility, the Integrated Scheduled Waste Management Centre
(ISWMC) at Bukit Nanas, Negeri Sembilan.

Solids wastes generated during the operational phase of the Advanced Materials Plant
include:

Residues from the physio-chemical processes within the Cracking & Separation
Plant;
Scale from neutralisation tanks and clarifiers in the Neutralisation Plant;
Scale from process piping and vessels that handle lanthanide sulphate solution;
Waste refractory from kiln maintenance;
Filter cloths from the FGD, NUF and WLP filtration processes;
Sludge from the Waste Water Treatment Plant (WWTP);
Scheduled wastes; and
General wastes.

With the exception of scheduled wastes and general wastes, all other wastes listed above
are classified as radioactive wastes by the Atomic Energy Licensing Board (AELB) and
thus the storage and management of these wastes must comply with the applicable
regulations under the Atomic Energy Licensing Act, 1984 and, endorsed by the AELB.
Matters pertaining to the on-site storage and management of these wastes come under the
purview of the Board. Lynas has engaged Malaysian Nuclear Agency (Nuclear Malaysia)
as the Radiological Consultants for this project and for the preparation of a Radiological
Impact Assessment (RIA) which evaluates the radiological impacts of the plant
operations to humans and the environment. A copy of the RIA has been submitted to the
AELB for approval as part of the Class A Milling Licence application requirements. The
Class A Milling Licence is required under the Atomic Energy Licensing Act, 1984 for
plants involved in the processing of radioactive materials.

For purposes of this EIA, only the non-radiological impacts pertaining to the waste
management are identified and assessed as the management of radioactive wastes comes
under the purview of the AELB.

In ensuring that the potential environmental impacts arising from the on-site storage of
the radioactive residue streams are minimised to a sustainable level, the Project
Proponent has developed a technically sound waste management strategy which is

8-14
described Section 3.2 Preliminary Comparison of Residue Disposal Options (Refer
Appendix 3). It is recommended that this strategy be incorporated into the
Environmental Management Plan (EMP) prepared for operational phase and endorsed by
the AELB and the DOE for implementation.

The Project Proponent has commissioned a conceptual engineering design of the RSF,
taking into account key engineering design and environmental considerations. Each
residue stream has different characteristics in terms of water content, its composition and
radioactivity. Design considerations of the RSF as well as residue management are
dependent on these characteristics. One conceptual design scenario has been presented
to the AELB and are currently under evaluation.

The key features of the RSF design which provides for the protection of environmental
resources, namely soil and groundwater are summarised below:

Fill material will be placed at low-lying areas to ensure that the base of the RSF is at
least 1 m above groundwater level. It is recommended that the fill material comprises
soils with low permeability;

All residue storage cells will be lined with 300 mm low permeability compacted clay
liner overlain by a 1 mm thick HDPE liner to prevent seepage into the underlying
soil and groundwater;

All supernatant liquors and rainfall runoff from FGD and NUF residue cells will be
collected and pumped via pipeline to a HDPE-lined FGD/NUF surface water
retention pond with capacity for the 1 in 100 year storm event based on climatic data
for the region. Water from this pond will be directed to the Waste Water Treatment
Plant (WWTP). The treated waste water will then be discharged off-site into an
external earth drain which discharges into Sungai Balok. All off-site discharges will
be monitored to comply with the limits stipulated in Standard B of the
Environmental Quality (Sewage and Industrial Effluent) Regulations, 1979;

Supernatant liquors and rainfall runoff from the WLP residue cell will be pumped to
a separate HDPE lined surface water retention pond (with capacity for the 1 in 100
year storm event based on climatic data for the region) and subsequently recycled
into the cracking and separation process stream. No off-site discharge is anticipated;

During heavy rainfall and in particular the monsoonal wet season the surface of the
residue is expected to become wet, soft and slippery making placement of residue
during this period problematic due to the poor trafficability of the residue surface.
Therefore, a temporary cover may be required to keep the area of active residue
placement dry during the wet season. A potential solution to this problem is to size
the drying shed with sufficient capacity so residue can be stockpiled during the wet
season awaiting placement in the RSF during drier weather;

To ensure a long term slope stability, perimeter RSF embankment walls will be
designed and built with a gentle gradient of 3H:1V. In addition, the maximum height
of embankment will be limited to 8 m above existing ground level. The preliminary

8-15
slope stability assessment indicates that the proposed embankment fill height of 8m
results in a FOS of less than the acceptable minimum of 1.3 under short-term
undrained conditions. This can be overcome by the placement of an additional 1.0m
of well compacted select fill across the RSF area. Further assessment of the
consolidation behaviour of the subsurface soils is required to confirm the short-term
stability of the embankments; and

Erosion protection in the form of rip-rap or geotextiles will be incorporated.

In addition to constructing the RSF which incorporates environmental protection
features, the Project Proponent is also exploring the potential beneficial uses of each of
the three residue streams. The reuse of residues will significantly reduce the quantity of
residue for on-site storage and the allocated footprint for the RSF within the site. Details
of these reuse options are presented in the Preliminary Comparison of Residue Disposal
Options presented in Appendix 3.

Scheduled Wastes

Scheduled wastes generated at the site can either be recycled or disposed at approved
facilities. There is currently a market of spent oils, solvents, lead batteries, oil filters and
paints. These can be readily sold to DOE-licensed recyclers. There are a few facilities
licenced to recover spent catalyst, waste oil, spent hydraulic oil and chemicals that are
discarded or off-specification located nearby in the Gebeng Industrial Area and Teluk
Kalong Industrial Area.

Scheduled wastes which cannot be recycled but require disposal will need to be disposed
at the Integrated Scheduled Waste Management Center (ISWMC) operated by Kualiti
Alam which is presently the only licensed facility in Malaysia. Upon signing a contract
with Kualiti Alam, the company will arrange for their marketing division to coordinate
the entire packaging and transportation of the wastes to the integrated facility.

8.6 AMBIENT AIR


Construction activities most likely to result in the emission of fugitive dusts include:

Site preparation works such as excavation, levelling, compaction and trenching;
Movement of heavy construction vehicles and machinery within the site and during
transportation operations;
Material handling (delivery, unloading and use of construction aggregates and
structural fill); and
Material/soil tracked out of the site and deposited on local roads.

The exhaust emissions emitted from vehicle and machinery engine exhaust emissions
will contain NO
x ,
SO
x ,
CO, volatile organic compounds (VOC), particulates and smoke.

8-16

The frequent occurrence of rainfall (The average annual rainfall recorded at the station
over the period 19512005 is 2,957 mm with an average of 189 rainy days annually) and
the low wind speeds (mean of 3 m/s) at the plant site will tend to reduce fugitive dust
entrainment from sources (e.g. stockpiled materials etc.), but will have limited effects on
entrainment from mobile dust sources (e.g. mobile plant, spoil transfer operations).

Based on the above, the impacts are predicted to be generally localised within an
estimated 100 m radial distance of the works area, with the implementation of standard
dust control measures within the construction works site. The impacts are anticipated to
be short-term, lasting during the construction phase.

Impacts arising from exhaust emission from construction plant and vehicles will depend
on the number of vehicles and plant stationed on site. Details on the number and type of
construction machinery had not been firmed up at the time of reporting. However, the
impacts arising can be effectively mitigated with proper and regular maintenance of the
emission sources which would prevent the generation of excessive noxious emissions
and black smoke.

The potential air quality impacts arising from the plant site during construction works
will be mitigated by observing standard dust suppression measures as described below.

Carrying out regular surface damping or wetting on general site areas, stockpiled fill
and aggregates especially during dry ambient conditions. Effective wetting of at least
the initial 6 cm of the top soil is necessary. This would bind the loose soil particles,
increase its effective size and weight, and reduce the amount of fugitive dust
generated;

Providing side enclosure and covering of any aggregates or stockpiles;

Ensuring that all hardstanding areas and access roads within the site remain wet
during use;

Ensuring construction vehicles moving in/out of the site do not track soil off-site and
deposit soil on public roads by providing wheel-washing facilities at the
ingress/egress points. These facilities will be equipped with (1) a temporary concrete
hardstanding of sufficient size to accommodate a standard sized vehicle and equipped
with a sump; and (2) high pressure water jets.

All vehicles operating within the plant site and especially within the construction
works area and the ingress/egress points will adhere to speed limits not exceeding 30
km/hr.

A 50 m road stretch on the public road before and after each ingress/egress point into
the site will be wetted regularly to minimise dust emissions from the surface of the
road.


8-17
All construction vehicles transporting dusty materials should be secured with
tarpaulin sheets to prevent the escape of fugitive dust.

Open burning on the site premises is strictly prohibited on-site. All construction spoil
must be transported to approved disposal sites by licensed contractors.

The control of vehicular emissions can be achieved by observing good construction
practice procedures such as:

Turning of equipment when not in use;
Lorries/trucks waiting for more than 10 minutes should turn off their engines; and
Regular maintenance of construction vehicles/equipment.



Cracking & Separation Plant

Air emission sources identified within the Cracking & Separation Plant include the
following:

Tunnel furnace used for product calcination;
Boiler used for steam generation; and
Waste gas scrubber system.

As both the tunnel furnace and the boiler will be fuelled by natural gas, no impacts are
predicted from these sources. The primary source of air emissions arising from the plant
during the operational phase will be the waste gas scrubber system at the Cracking &
Separation Plant. To determine the dispersion pattern of the pollutants released from the
waste gas scrubber stack and to quantify their respective concentrations in the
atmosphere, the BREEZE Industrial Source Complex Short Term Version 3 with
Plume Rise Enhancements (BREEZE ISC3 Prime) air dispersion model was used to
predict the potential ground level impacts arising from emissions of the waste gas
scrubber stack.

8-18

The BREEZE ISC3 Prime model was used to predict the maximum ground level
concentrations over 1-hour, 24-hour and annual averaging periods to correspond with the
relevant ambient air quality criteria for each of the modelled compounds.

As the emission from the waste gas treatment system (wet scrubber) is the primary air
pollution source, an air dispersion modelling was carried out for this point source.

In developing the air dispersion model, two operational modes have been identified for
the proposed plant, namely (1) normal and (2) emergency operations. Under normal
operations, small quantities of sulphur dioxide (SO
2
), hydrogen fluoride (HF), sulphuric
acid mist (H
2
SO
4
) and particulate matter (PM) will be emitted from the waste gas
treatment system following treatment of the kiln off-gas. Under emergency operations,
SO
2
and H
2
SO
4
mist will be emitted from standby caustic scrubbers following treatment
of emissions from the kilns operating in shutdown mode.

A summary of the air dispersion modelling findings are presented below:

maximum GLCs of SO
2
, H
2
SO
4
, HF and PM
10
below all of the applicable AAQ
guidelines and STELs, across the model domain, for 1, 2 or 4 kilns operating
under normal conditions and where the highest concentrations are predicted to
occur in relative close vicinity to the plant;

maximum GLCs of SO
2
below all the applicable AAQ guidelines and STELs,
across the model domain, for 1, 2 or 4 caustic scrubbers operating under
emergency conditions;

maximum GLCs of H
2
SO
4
below the corresponding STEL for 1, 2 or 4 caustic
scrubbers operating under emergency conditions; and

an exceedence of 1-hour H
2
SO
4
AAQ guidelines under emergency operating
conditions, although the worst-case probability of this operating mode occurring
and resulting in an exceedence is 101 in a million.

The results of the air dispersion modelling indicate that the proposed Advanced
Materials Plant is not expected to result in unacceptable air quality impacts under normal
operations for SO
2
, H
2
SO
4
, HF and PM
10
and while exceedences of 1-hour H
2
SO
4
AAQ
guideline are predicted under emergency operating conditions, the frequency of this
occurring is considered low.

8-19

The air dispersion modelling has been carried out based on the design stack height of the
proposed waste gas treatment system, the emission rates and pollutant concentrations of
the treated/exit gas, heights of the building structures proposed within the plant site and
local conditions such as the meteorological conditions and the site (and immediate
surrounding) topography. Therefore, in achieving the desired efficiency and meeting the
predicted ground level concentrations of the pollutants under assessment, i.e. SO
2,
HF,
H
2
SO
4
mist and PM
10,
the waste gas scrubber design parameters will need to be
maintained. In the event, there are changes in the design prior to project implementation,
it is recommended that the air dispersion model be re-run and the assessment reviewed.
This is to ensure the ground level concentration for the pollutants concerned meet the
regulatory requirements.

8.7 BIOLOGICAL RESOURCES

8.7.1 Construction & Operational Phases

The biological resources affected in the construction phase of the project are:

Terrestrial flora and fauna species at the propossed Advanced Materials Plant site;
and
Aquatic biological resources within Sungai Balok.

As discussed in Chapter Four of this document, prior to the development of the Gebeng
Industrial Estate (GIE) in the 1990s, the area was waterlogged peat swamp forest.
Ecological impacts arising from the land conversion activities have since occurred at the
site. The various species of fauna that inhabited the area are expected to have perished or
migrated to other forested areas nearby while the original vegetation would have been
completely cleared away.

As the site had remained vacant (undeveloped) since the land conversion, it has been
progressively colonised by secondary vegetation comprising the more common, hard and
invasive species. Only sparse vegetation was observed across the site comprising
secondary dryland scrub vegetation with low species diversity. No faunal species of
conservation value is expected to occur. Any remaining vegetation removed is not
significant or of conservation value.

Overall, the impact from the site activities on the terrestrial flora and fauna at the site is
not considered significant.

Based on personal correspondence with the Department of Fisheries in Kuantan, the
fisheries resources within Sungai Balok are not harvested for commercial fishing and
livelihood. The local fishermen from the main fishing village of Kampung Balok carry
out deep-sea fishing. Only recreational fishing is carried out along Sungai Balok by

8-20
anglers. Common names of fish species typically found in the river include Siakap Puteh,
Siakap Merah, Sembilang, Duri and Baung,

8-21

8.8 SOCIO-ECONOMIC IMPACTS


Employment of workers to make-up the construction labour force project will be
necessary during the construction phase. Although priority will be given to local
residents working in this sector, employment of foreign labour may be expected in the
event of local labour shortage. If the labour force is housed on-site, proper
accommodation facilities will have to be provided with basic amenities such as potable
water supply, electricity, solid waste disposal and sanitary treatment facilities.

The employment of foreign labour may result in the import of communicable diseases
not indigenous to the area, for example malaria, dysentery and cholera which could
spread to the local residents, in the event of poor hygiene practices, as these diseases are
vector borne or waterborne.

To prevent undue aberrations with the local community, the nominated EPCM
Contractor when hiring foreign labour must ensure that the workers are legally registered
with the Department of Immigration.


Significant long-term positive socio-economic impacts are predicted during the
operational phase of the project at a regional and national level.

8.9 CONCLUSION
The findings of this report indicate that the predicted environmental impacts arising from
the construction and operational phases of the Advanced Materials Plant can be
effectively mitigated and reduced to meet regulatory limits with the implementation of
appropriate mitigation measures. The findings also show that there are no detrimental or
harmful impacts which cannot be mitigated or, are unavoidable.

The recommended mitigation measures include technologically sound practices and
environmental best management practices that will minimise the potential impacts to
sustainable levels. To ensure the effectiveness of the mitigation measures, an
Environmental Management Plan which includes requirements for periodical
environmental monitoring and audits for the construction and operational phases of the
project will be developed and implemented. This is to ensure that all recommendations
of this EIA and the requirements of the relevant government agencies are executed by
Lynas.

The Project Proponent is committed to operating the plant in an environmentally
sustainable manner, in compliance with all prevailing environmental regulations.

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PRELIMINARY ENVIRONMENTAL IMPACT ASSESSMENT AND

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