IAEA TECHNICAL COOPERATION PROJECT INT2019 INTERREGIONAL ... · EXAMPLE CHECKLIST – MINE ROCK...

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)

K Scissons Oct 2019 2

REGULATORY FRAMEWORK

3 K Scissons Oct 2019

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.


APPLICATION STEPS, WITH EIA


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!


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?


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.


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

K Scissons Oct 2019 9 *

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


- K Scissons

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.


- 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.

K Scissons Oct 2019 12 - K Scissons

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)


Regulatory Situation

Agencies potentially involved in regulating uranium mines

and processing facilities can include, for example:

OTHERS ?

NATIONAL APPROACH


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.


COMPLIANCE AND ENFORCEMENT


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?)


Key L. Mill Control Room,

Canada (K. Scissons)


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.


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)


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.

K Scissons Oct 2019 21 Texas Ranger

- K. Scissons

CONSTRUCTION PHOTOS – CANADA


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

K Scissons Oct 2019

2

3

- K Scissons

Niger – N. Tsurikov

IAEA REFERENCE DOCS. - EXAMPLES

24

Thank You!

K Scissons Oct 2019

IAEA TECHNICAL COOPERATION PROJECT INT2019 INTERREGIONAL ... · EXAMPLE CHECKLIST – MINE ROCK...

Documents

Transcript of IAEA TECHNICAL COOPERATION PROJECT INT2019 INTERREGIONAL ... · EXAMPLE CHECKLIST – MINE ROCK...