Uranium Mining in Virginia Scientific, Technical, Environmental, Human Health and Safety, and Regulatory Aspects of Uranium Mining and Processing in Virginia (2012) / Chapter Skim
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8 Best Practices
8 Best Practices
Pages 258-276
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From page 258... ...
Good operating practice is for site and waste remediation to be carried out on a continuous basis during ore recovery, thereby reducing the time and costs for final decommissioning, remediation, and reclamation. Regular and structured risk analyses, hazard analyses, and operations analyses should take place within a structured change management system, and the results of all such assessments should be openly available and communicated to the public.
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From page 259... ...
• Some of the worker and public health risks could be miti gated or better controlled if uranium mining, processing, and reclamation are all conducted according to best practices, which at a minimum for workers would include the use of personal dosimetry -- including for radon decay products -- and a national radiation dose registry for radiation- and radon-related hazards; and exposure limits lowered to at least the levels for radon, diesel gas and particulates, occupational noise, and silica hazards rec ommended by the National Institute for Occupational Safety and Health (NIOSH)
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From page 260... ...
. Full use of this period will be essential for development of a regulatory culture that promotes environmental and human health protection, for instituting a broad range of human health and environmental baseline monitoring activities, for development of a robust legal and regulatory infrastructure, and to assemble a management team that is responsive both to the regulatory process and to the full range of citizen and stakeholder needs.
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From page 261... ...
In addition, ongoing communication with other facilities, both operating and in closure, is essential to capture lessons learned and incorporate them through an adaptive management approach to avoid public health or environmental consequences that were not anticipated at the outset of the project. Need for Qualified Experts Development of a mining and/or processing project should use the expertise and experience of professionals familiar with internationally accepted best prac tices, to form an integrated and cross-disciplinary collaboration that encompasses all components of the project, including legal, environmental, health, monitoring, safety, and engineering elements.
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From page 262... ...
Moreover, the regulatory buildup may have to overcome established and entrenched regulatory cultures and increas ingly limited resources. A generic scenario (Figure 8.1)
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From page 263... ...
BEST PRACTICES FIGURE 8.1 Possible stages and timing for development of a conceptual uranium mine as well as the stages and timing for develop Possible develop ment of a regulatory infrastructure specific for uranium mining and processing.
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From page 264... ...
An additional important consideration is that because mining projects and mining impacts are by their nature localized, modern best practice is for project implementation and operations to -- wherever possible -- provide benefits and opportunities to the local region and local communities. Literature Resources Although not seeking to endorse or recommend any specific best practices in existing literature, the committee noted that many of the overarching themes that it identified coincide with concepts put forward by the World Nuclear Association (WNA; see Appendix C)
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From page 265... ...
. In developing best practices for setting radon decay product exposure limits for uranium miners and processors, it is important to consider that NIOSH recommended in 1985 a permissible exposure limit 75 percent lower than the current U.S.
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From page 266... ...
Department of Labor MSHA or OSHA legally enforceable standards as currently promulgated. Best Practices for Environmental Monitoring A well-designed and -executed monitoring plan is essential for gauging performance, determining and demonstrating compliance, triggering corrective actions, fostering transparency, and enhancing site-specific understanding.
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From page 267... ...
A multitiered strategy that follows a rigorous sampling protocol, where the mining and processing facility, local community groups, and local government agencies conduct parallel monitoring programs, can be an effective strategy to address multiple concerns and maintain trust. Accordingly, before any uranium mining and/or processing facility is established, modern best practice requires that a comprehensive baseline environmental monitoring and assessment program be conducted, incorporating three components: 1.
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From page 268... ...
During construction and throughout all the other uranium mining and processing steps where dust may be generated, control measures would include dust suppression systems, spraying or wetting dust, use of tacti fiers, and washing construction equipment before it leaves the site. Underground mines should have extensive exhaust systems to protect workers from exposure
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From page 269... ...
Site-specific conceptual and numerical models are essential to quantify the understanding of the full earth system, determine appropriate mitigation and response strategies, and develop and modify a monitoring plan. Therefore, these models need to undergo annual updates and independent reviews, to incorporate new understanding gained from analysis of the monitoring data or new knowledge (e.g., changes to process design and operation)
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From page 270... ...
The vulnerability analysis will be informed by historical data for emergen Best Practices for Regulation and Oversight Regulatory programs are inherently reactive. Accordingly, standards con tained in regulatory programs represent only a starting point for establishing a protective and proactive program for defending worker and public health, and the environment.
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From page 271... ...
Training and exercising with off-site responders will allow them to be comfortable responding to emergencies at the facility. In Canada, because there is consistency of regulatory authority in the regula tion of uranium mining, processing, reclamation, and long-term stewardship, emer gency planning for uranium mines and mills is summarized in a single regulatory guide.
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From page 272... ...
Three broad principles should guide closure planning for uranium processing or mining sites: • Closure planning should be anticipatory. • Closure planning should be iterative and adaptable.
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From page 273... ...
It is quite possible, however, that the duration of risks from residual contamination will exceed the institutional capacity to reliably perform stewardship activities. It is widely recognized that
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From page 274... ...
To encourage and facilitate best management practices and social responsibility commitments to local communities, it is nec essary to take advantage of continual improvement in technologies and develop performance-based and risk-informed regulations and policies. In the event that the uranium mining moratorium is lifted, the statutes and regulations that enable the development of a mining and/or processing facility would ideally be written to ensure minimal permanent impact on the environment and protect public health.
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From page 275... ...
• The committee recognizes that the federal regulations governing uranium processing are currently under consideration for revision by the USNRC. Additionally, the USEPA is reviewing and potentially revising its health and environmental standards for uranium processing facilities.
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From page 276... ...
There is only limited experience with modern underground and open-pit uranium mining and processing practices in the wider United States, and no such experience in Virginia. At the same time, there exist internationally accepted best practices, founded on principles of openness, transparency, and public involve ment in oversight and decision making, that could provide a starting point for the Commonwealth of Virginia were it to decide that the moratorium should be lifted.
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