BHP Billiton PowerPoint Template and Style Guide
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Environmental protection and non-
human biota: emerging regulatory
implications David Kruss
Advisor Environment, Uranium Projects
16 August 2012
Includes contribution from Jim Hondros
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Overview
Regulatory Framework
Expansion approval conditions
Monitoring program review
Airborne emissions program
Environmental radiation
Setting the reference levels
Monitoring program in depth
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 3
Unique regulatory framework
Roxby Downs (Indenture Ratification) Act 1982 requires;
compliance with codes or recommendations from;
– ARPANSA* (e.g. RPS9 - Code of Practice and Safety Guide for Radiation Protection and Radioactive Waste Management in
Mining and Mineral Processing 2005)
– ICRP
– IAEA
Use best endeavours to keep radiation exposure to workers and public at levels consistent with ICRP103
A 3 year Environmental Protection and Management Program (EPMP)
The EPMP incorporates the requirements of a radioactive waste management plan (RWMP) from ARPANSA RPS9
ISO14001:2004 certified and made available to public
Monitoring programs related to environmental radiation
Airborne emissions
Waste
Environmental radiation
*ARPANSA - Australian Radiation Protection and Nuclear Safety Agency
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 4
Olympic Dam Expansion
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012
In October 2011 BHP Billition received approval from State and Federal Governments for a major
expansion;
Development of an open pit mine capable of delivering 40 million tonnes/year ore
Construction of new process plant to produce 750,000 tonnes copper/year and 14,000 tonnes uranium
Will take over 5 years to reach ore
Slide 5
Expansion approval conditions
Draft and Supplementary EIS written 2007-2011 and consideration of NHB was quite new – no
Australian regulatory codes or safety guide
NHB assessment performed for Supplementary EIS
No commitments from the company relating to NHB in EIS
Both State and Federal approved expansion and included specific conditions relating to
Airborne emissions (dusts, gases and radon)
Non human biota (including reference levels and leading indicators for NHB)
Radioactive waste rock and tailings
Licensing
No changes to licence to mine radioactive material until pit has substantially progressed
Amendments to some non radiation environment licences
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 6
Airborne emissions monitoring
Existing program
Isokinetic stack sampling of process plant stacks
Fugitive emission monitoring using deposition monitors (data feeds to NHB)
High volume air sampling and radon decay product sampling at critical populations to assess doses to
public
Changes for expansion approval conditions
Deployment of real time dust monitors at critical populations and north and west of mine lease
Monitoring PM10, PM2.5, meteorology and radon/radon decay products
TSP using high volume air samplers
– Using wind activation to differentiate between mine and background sectors
Sampling according to relevant Australian Standards
Additional fugitive emission sample points once pre-mining underway
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 7
Air quality monitoring system (AQMS)
Roxby Downs Olympic Dam
Hiltaba Village
Wind activated high
volume sampler
Radon/Radon decay
product monitor
Data captured via SRA
EnviroSys
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 8
AQMS challenges
Real time dust
Only TEOM and BAM1020 certified to Australian & US EPA standards
These instruments are high power users and may require air conditioning
EBAM works similar to BAM1020 however not certified Australian & US EPA standards
EBAM easily powered off solar
2 year side by side performance trial of all 3 instruments showed EBAM consistent with TEOM
and BAM1020
Received approval to use EBAM
EBAM site TEOM site
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 9
Environmental radiation
New monitoring program to address new approval conditions and centralise radiation
monitoring obligations
Cross reference index to RPS9 RWMP requirements
New items
Radionuclide analysis of soils at dust deposition sites
Tri-annual radionuclide analysis of flora and fauna
Annual ERICA assessments
Addition of radon monitoring (previously only measured radon decay products)
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 10
Non human biota approval conditions
State
“Radiation doses to non-human biota arising
from the expanded Olympic Dam operations
and radioactive waste management area are
as low as reasonably achievable”.
“The proponent must set a reference level for
impacts on non-human biota (interim criteria
for non-human biota may be set until such
time as an agreed national approach is
determined)”.
Federal
“Target Criteria must reflect a level of impact that is as low as reasonably achievable for radiation exposure to humans, and must be minimised to the lowest reasonable levels for Non-human Biota.”
“..... must include Target Criteria for radiation exposure in the form of a radiation Dose Constraint for Members of the Public and a Reference Level for impacts on Non-human Biota. “
“The program required under condition 4 must demonstrate that the Approval Holder uses Best Practicable Technology to ensure exposure of the public to radioactive releases is as low as reasonably achievable and exposure of Non-human Biota is also minimised to the lowest reasonable levels”
“Target Criteria are measurable standards or specification of parameters that reflect a level of impact that is as low as reasonably achievable or minimised to the lowest reasonable levels for non-human biota. Practices must be reviewed if criteria are exceeded.”
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 11
Setting the reference level / target criteria
EPMP Heading Aim NHB Specific
Environmental Outcome The overall desired
outcome
No significant adverse
radiological impacts to
reference plants and
animals from ODC’s
activities
Compliance Criteria The level at which the
regulator can take action
(or the Minister instigate
action)
Deposition of project
originated 238U less than 25
Bq/m2/y at the non-human
biota assessment sites
Leading Indicator The level that indicates that
the company are on a path
to exceeding the
compliance criteria
Indications that a reference
level of 10 µGy/h for
impacts on NHB above
natural background will be
exceeded
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 12
Setting the reference level / target criteria
Reference level is not an indicator of compliance rather than a level which may require action
Adopted a reference level of 10 uGy/h (ERICA default)
Exceeding the reference level of 10 uGy/h triggers the need to further investigate emissions and perform ERICA assessment at Tiers 2 and 3.
Calculated annual deposition rate required to remain below the reference level to be 6 Bq/m2/y U238 (in secular equilibrium).
Compliance criteria 25 Bq/m2/y (2 g/m2/m) at critical locations (eg Roxby Downs)
Criteria will be reviewed once local regulations introduce NHB
1 g dust ≈ 1 Bq/g U238
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 13
NHB monitoring
Existing passive dust deposition monitoring
sufficient for regular ERICA assessments
Additional monitoring points to be added once
pre-mining begins
Leading indicator will be 2 g/m2/m. If samples
return above then we have the option of
radionuclide analysis
Tri-annual soil, flora and fauna monitoring used
to derive site specific concentration ratios
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 14
Complications
Bulk of fugitive emissions are from mine and rock storage facility – uranium series in secular
equilibrium
Can also have non equilibrium emissions from process plant namely;
Uranium oxide calciner scrubber stacks (U238, U234)
Smelter stacks (Pb210, Po210)
Tailings dams ( U238 1/7th of ore activity, Th230 onwards same as ore)
Smelter contribution difficult to resolve due to background Pb210
Historic monitoring shows minimal smelter contribution outside mine lease
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 15
Summary
One of the first operations to receive specific NHB conditions.
Able to incorporate additional NHB obligations into existing program with minimal additional
monitoring
Modelling shows that we should remain compliant under worse case scenario
Well positioned to adopt any new codes/recommendations.
David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 16