IAEA TECHNICAL COOPERATION PROJECT INT2019 INTERREGIONAL WORKSHOP ON CASE STUDY OF
CONVENTIONAL URANIUM PRODUCTION FROM EXPLORATION TO CLOSURE
14-18 OCTOBER 2019
PRAGUE AND DOLNI ROZINKA, CZECH REPUBLIC
Regulatory oversight at different
project phases of a uranium mine
and processing facility
REGULATORY SYSTEMS AND
LEGISLATIVE FRAMEWORK - REVIEW
A legislative and statutory framework shall be established to
regulate the safety of facilities and activities.
A regulatory body shall be established and maintained which shall
be effectively independent.
The regulatory body shall be provided with adequate authority and
power, and ensure it has adequate staffing and financial resources to
discharge its assigned responsibilities, like inspections.
Adequate regulatory arrangements shall be made for items like:
• Exploration, Assessment, Construction, Operation;
• Decommissioning, close-out and remediation;
• Safe transport; and
• International obligations (safeguards, and security)
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REGULATORY FRAMEWORK
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APPLICATION REQUIREMENTS - EXPLORATION
Requirements for an exploration* project include:
• applicant’s name and business address;
• a general description of the proposed activities and their
schedule;
• a description of the location of the proposed activity, including site
access;
• a description of the proposed methods for undertaking the activity;
• results of the Safety Assessment
• a list of the categories of material proposed to be explored;
• the plans for radiation protection, environmental management,
waste management and community engagement; and,
• a site remediation and restoration plan.
• *More intrusive exploration techniques require more scrutiny.
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APPLICATION STEPS, WITH EIA
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Public Comment*
Final EIA and Tech. Reg. Review
Public Hearing or Formal Decision
Licensing Doc. Review, Acceptance
License Hearing Or Decision
EIA* : * NOTE: Country Env’l. Impact Assessment
Review Process Followed
Includes Public, Interested Parties understanding
REGULATOR’S REVIEW PROCESS
Considerations, as you begin:
Have all the Act, Regulations, Regulatory Requirements (e.g., license conditions) been identified?
Have Guidelines been used successfully by the applicant, or been ignored?
Have Approval or acceptance criteria been established by the regulators, to assess the application against (the “yardstick”)? All parties benefit if the “rules” are understood… think football!
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REGULATOR’S REVIEW PROCESS Main Areas of Review for Mine, ISL, Processing:
Site characterization complete?
Act and Regulations requirements fulfilled?
Design Principles and Hazards identified?
Construction methods, controls adequate, as-built plans submitted?
Management Systems and Human Performance Programmes ok?
Radiation and Environmental Protection
Conventional Safety
Water Management
Waste Management – mine rock, tailings, etc.
Transportation
Emergency Planning
Site Security
Decommissioning, and Financial Guarantees
Stakeholder Engagement?
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RESPONSIBILITY FOR SAFETY
The government shall stipulate that compliance with regulations and requirements established or adopted by the regulatory body makes the licensee or operator responsible for the facility or an activity.
In other words, the operator’s prime responsibility is for safety; the regulator’s role is to verify they are in compliance.
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EXAMPLE CHECKLIST – RADIATION
PROTECTION
Area classification, work
Monitoring plan
(occupational, public,
environment)
Worker training, monitoring
equipment and
instrumentation
How will doses remain below
dose limits?
ALARA demonstrated
Management control of work
practices
Control of Worker and
Public exposures
Quantity and concentration
of any nuclear substance
released
Radn. Work
Emergencies
Record keeping
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Swiping drum - K Scissons
EXAMPLE CHECKLIST – WATER
MANAGEMENT
Mine site watersheds identified
Flow rates (min., extreme)
Site water balance
Water management measures proposed
Diversion of clean waters
Groundwater (direction, recharge, discharge, etc.)
Acid mine, waste drainage
Water usage, make-up water
Water recycle
Fresh water diversion, interception ( plus groundwater)
Consolidated waste streams
Designs for extreme weather
Waste water quality, quantity
Geological materials and input to processing, tailings, effluent, construction
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EXAMPLE CHECKLIST – TAILINGS
MANAGEMENT Site Characterisation
Hydrology, Hydrogeology
Climate, Topography
Geology/Geomorphology
Seismic Conditions
Soil Geochemistry
Construction Materials (availability and properties)
Tailings characterization
Above or below grade
Monitoring, maintenance
Releases (air, water)
Storage capacity (freeboard)
Spillway/no release
Erosion protection of slopes
Diversion channel design
Seepage control/groundwater
Construction specifications
Quality control (testing and qualified inspection plans)
Closure plan, cover, etc.
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- Areva
EXAMPLE CHECKLIST – MINE ROCK
Site Characterization
Hydrology, Hydrogeology
Climate
Topography, water courses
Geology/Geomorphology
Geochemistry
Waste rock, clean rock characterization (AMD?)
Temp. or long term storage
Construction use and control
Returned to mine workings
W. rock pads – lined or not
Erosion protection of slopes
Diversion or runoff channels design
Seepage control/groundwater
Construction specifications
Quality control (testing and qualified inspection plans)
Closure plans, cover, etc.
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NATIONAL COLLABORATION
National Scale:
Nuclear Agency
Environment, Natural Resources
Export, Trade and Commerce
Health
Revenue
Transport
State/Local Scale:
Mines and Resources
Environment
Water and Natural Resources
Health
Land Titles
Labour (Mine Safety)
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Regulatory Situation
Agencies potentially involved in regulating uranium mines
and processing facilities can include, for example:
OTHERS ?
NATIONAL APPROACH
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Assessment
Controls Monitoring
Joint Regulatory
Defence-in-depth,
under a
coordinated
harmonized regime
or approach, will
benefit all. A
written MoU
solidifies the
relationship.
AUTHORIZATION STEPS : FOLLOW YOUR REGULATORY PROTOCOLS
Have all questions been technically answered and all requirements satisfied?
Have reviews been approved by supervisors, if required (high risk, more scrutiny)?
Has the appropriate approval authority been identified (is this a license condition requiring highest approval)?
Coordination of approvals with other authorities required?
Timing of approval critical, timely?
Public interest or notification of approvals?
Does approval include conditions, limits, duration, or an expiry?
Approval follow-up: records, insp. plans, verify compliance.
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COMPLIANCE AND ENFORCEMENT
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Inspections
Corrective Action(s)
Doc. Reviews - CNSC
COMPLIANCE PROGRAMME -
INSPECTION Following GS-G-1.3, (IAEA, 2002) , the Compliance Inspection is in
accordance with approved or authorized activities:
• areas subject to inspection (high risk, critical systems)
• method of inspection to be used (photos, interviews )
• inspection samples taken, analysed, duplicated
• relevant technical information and questionnaires
• reporting requirements and practices for inspectors
• standards of conduct of inspectors (phase specific)
• enforcement policy, procedures and practices
• outcome of reviews of Operator’s reports ( in compliance?)
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Key L. Mill Control Room,
Canada (K. Scissons)
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RADIATION PROTECTION - INSPECTIONS
Management Controls in place, effective? • Risk assessments done and used
• Work and process controls
• ALARA program
• Training and Supervision sufficient
Engineering Controls in place, effective? • Operation or Remediation methods, ventilation and dust control
• Monitoring (internal and external)
• Individual dosimeters
• Continuous monitors with warning lights
• Area/time monitoring
• Time-distance-shielding
Administrative Controls in place, effective? • Dose limits, action levels, codes of practice, records
• National dose registry, medical surveillance in place
• Periodic and event reporting done Alpha Radon
Detector
(K. Scissons)
INSPECTION REPORTS
McArthur R. Mine, Canada
(K. Scissons)
Details of facility, activities, processes, systems inspected, assessed or reviewed;
A record of any deficiency or violation found, or contravention;
A record of discussions held with the site staff and managers;
A record of the manager’s initial response to any matter of concern drawn to their attention;
A record of the inspector’s findings or conclusions, including corrective or enforcement actions or recommendations, including their timelines.
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Contain:
PROGRESSIVE ENFORCEMENT Graded or progressive enforcement tools include :
Assess the significance of a violation by considering safety
consequences and any willful aspects of the violation.
Meetings with senior licensee executives
Written notices (recommendations, action notices);
Increased regulatory scrutiny (more inspections);
Formal Requests from the Head Regulator or another
authorized person
Monetary penalty* (ticket) issued by the regulator, without
court involvement, for violation of a regulatory requirement.
* Administrative in nature, and no criminal record associated with it. Burden of
proof less than that for criminal proceedings. Max $25,000 to $50,000 (Canada)
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PROGRESSIVE ENFORCEMENT (CONTINUED)
• Orders (based on country laws);
• Licensing actions (amendment or suspension of part of a licence, revocation of personnel certification, and revocation or suspension of a licence); and
• Prosecution, which may include significant monetary penalties or jail time depending on country laws and significance.
Regulatory Powers:
You can only take action that is permitted under your own Act and Regulations – or you become the law breaker !
Discretionary use is a learned technique.
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CONSTRUCTION PHOTOS – CANADA
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Port Radium, NWT - 1940’s - CNSC
Cigar Lake
McClean Lake
McArthur River
CNSC Inspectors, Specialist
Rabbit Lake
TMA Expansion
URANIUM PROCESSING FACILITIES
This area includes:
Processing plant (mill) - AREVA In-Situ Recovery
Central processing plant
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3
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Niger – N. Tsurikov
IAEA REFERENCE DOCS. - EXAMPLES
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Thank You!
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