Regulatory Philosophy And Requirements For Radiation Control In Canadian Uranium Mine-Mill Facilities

Dory, Aladar B.
Organization: Society for Mining, Metallurgy & Exploration
Pages: 3
Publication Date: Jan 1, 1981
INTRODUCTION Anyone familiar with the problems of hardrock mining will agree that the majority of the serious dangers present in mining are quite visible and obvious to any person reasonably familiar with the profession. Having unsecured, unscaled back over ones head, gives one a very good chance of ending up under a caved in mass of rock. Staying too close to a blast gives one almost a certainty of being hit by a flying rock. Too little oxygen in the air will very quickly lead to loss of consciousness and death. One walks only so much over deep, unsecured openings before he falls into them. It is because of this clear visibility of the conventional health and safety hazards that mining regulations in almost all jurisdictions world-wide are a more or less comprehensive collection of "shalls" and "must nots" of good common sense. When basic rules of common sense safe working practices are at stake, there is little room for dialogue and compromise. The mine inspector is then observing, during his inspection, how well the mine follows these common sense rules. RADIATION AS A HIDDEN DANGER Radiation in mines is a risk, the impact of which does not demonstrate itself immediately. It is first of all a potential risk. Two individuals exposed to identical radiation will almost certainly be effected differently, if at all. This is certainly true of exposures and doses one might encounter in the mines today. We hear very often the phrase: "there is very little known about the effects of radiation". It is one of the most misused and misunderstood half-true statements. I would doubt that there is any other carcinogen whose effects have been studied as extensively as the health effects of radiation. Where the statement is correct is regarding the knowledge of the quantitative assessment of the risk of low level radiation exposures. The reason for this uncertainty is that the magnitude of their health effect is very close to the health effects of natural radiation, cosmic radiation and the effects of other carcinogens such as industrial pollution, hydrocarbons from cars and other chemicals we have grown accustomed to using. As far as lung cancer is concerned, the effects of wide use of tobacco probably outperforms any other single substance. All this having been said, the bottom line is still unchanged. Radiation exposure, in most cases mainly radon daughter exposure, was and still is one of the health hazards of uranium mining and as such has to be controlled to the best of our ability. Various jurisdictions have adopted different approaches to the control of radiation exposures of uranium minemill workers. The following sections of this presentation will attempt to explain the regulatory approach taken in Canada. THE CANADIAN REGULATORY PHILOSOPHY As indicated earlier, the health effects of low level radiation are quantitatively not yet defined and no proven threshold of radiation exposure exists. The Atomic Energy Control Board's (the Board's) regulatory system is based on the basic assumption that there is no absolutely safe limit of radiation exposure below which there are no health effects. Theoretically we should therefore strive to reach zero exposure. It is obvious that this objective cannot be reached in real life. The objective of the regulatory process therefore has to be to achieve radiation exposures of the workers that are as low as reasonably achievable, social and economic factors taken into account. This, of course, is the internationally acclaimed ALARA principle put forward by the International Commission on Radiological Protection (ICRP). To avoid any misunderstanding it is worth emphasizing that the ALARA principle is applied to achieve exposures below the regulatory limits which must not be exceeded in normal operation of any nuclear facility including uranium mines and mills. The present regulatory limits for radiation exposures of atomic radiation workers are based on the recommendations of the ICRP and they are almost universally accepted. They should ensure that the risk from radiation exposure is not greater than the risk associated with working in a comparatively safe industry. Basically, there could be two extreme approaches to the regulation of uranium mining and milling. One extreme approach is to develop very extensive and detailed regulations and requirements covering all aspects of radiation protection. This is a somewhat autocratic approach to the regulatory process. This approach has two very serious shortcomings. If detailed requirements are set in regulations, due to the great variations of actual conditions at various mine-mill facilities, they have to be set as a compromise between the desirable requirements and those which could be met by practically all facilities. This approach takes away from the management of the facilities the initiative to strive for improved conditions. Requirements are spelled out in clear, understandable targets and the only worry of the management is to comply with these targets. One of the basic duties of management is to manage the operations in the most effective way with the maximum health and safety of the workers in mind.
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