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Criteria and procedures for recording and reporting incidents at South Australian uranium mines

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Introduction

This reporting procedure addresses incidents involving the unplanned release of radioactive process materials, radioactive liquids or radioactive wastes associated with the physical and chemical processing of uranium ores.

Incidents that require reporting under the Work Health and Safety Act 2012, the Dangerous Substances Act 1979 and the The Environment Protection Act 1993 (but see following note) shall be reported as normally required under these Acts.

NOTE: The Environment Protection Act 1993 is affected by amending provisions that have not yet come into operation or taken effect. Only amendments that have commenced are incorporated.

The aim of this procedure is to ensure compliance with conditions attached to the Licence to mine or mill radioactive ores issued under the Radiation Protection and Control Act 1982, and to ensure radiation exposures to workers, members of the public and the environment are as low as reasonably achievable.

All written reports of incidents shall be made on the approved Incident Report Form.

It is proposed that:

  • The efficacy of the procedure should initially be reviewed within 12 months. The review will take account of any changes in mine operations, technical difficulties encountered, the interaction of this procedure with the requirements of other applicable Acts and Regulations, and the appropriateness of
    current recording and reporting levels. The procedure should be regularly reviewed thereafter.

In applying the proposed reporting procedure, it is acknowledged that processing plants, wellfields, evaporation ponds, tailings dams, etc are 'disturbed' optional areas and will be subject to an approved clean up and rehabilitation program at the completion of the project. The reporting procedure places
emphasis on events which may result in unplanned release of radioactive process materials, radioactive liquids or radioactive wastes to the 'undisturbed ' environment, or any unplanned exposures to workers or members of the public.

The procedure is considered 'generic'. Other site-specific requirements may also be applied to particular operations as necessary.

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Reporting and recording procedure

The following reporting and conditions are be applied:

General requirements

Report
  • Any defect, due to design or malfunction, discovered in the mine, mill, plant, equipment or working procedure, that is likely to lead to an urgent change in plant, equipment or work procedure in order to keep radiation doses as low as reasonably achievable.
  • Release or loss of control of radioactive process materials, liquids or wastes, leading to the accidental exposure of a worker to radioactive materials through inhalation, ingestion or significant contact.
  • Unplanned dispersal to the atmosphere of any radioactive process materials through failure of a section of the plant or by an abnormal event (e.g. fire or explosion).
Record
  • The results of an investigation which reveals any defect, due to design or malfunction, discovered in the mine, mill, plant, equipment or working procedure, that is likely to cause significant increase in radiation exposure, together with the causes and resulting actions taken.

Undisturbed environment 

Report
  • Unexpected degradation or defect in the in situ recovery (ISR) trunklines, Tailings Retention System (TRS) pipelines and structures, pipelines or structures associated with Evaporation Ponds or Storage Ponds that, unless remedied, is likely to lead to a reportable release of radioactive process materials, liquids or wastes.
  • Any unplanned release of radioactive process materials, liquids or wastes to the undisturbed environment.
  • ISR mining fluid underground excursions.
  • Release of radioactive process materials, liquids or wastes which enter or threaten to enter an ephemeral watercourse.
Record
  • Any unplanned release to the surface of more than 10 m3 of natural groundwater.

ISR wellfields

Report
  • Any unplanned release of more than 10 m3 of radioactive liquids.
Record
  • Unplanned release to the surface of more than 10 m3 natural groundwater.
  • Any unplanned release of more than 1 m3 of radioactive liquids.
  • Unexpected degradation or defect in ISR lateral lines that, unless remedied, is likely to lead to a reportable release of radioactive liquids.

Process plant

Report
  • Any release of uranium concentrate outside secondary containment.
  • Release of more than 50 m3 of radioactive process materials, liquids or wastes beyond secondary containment, but contained within the engineered controls of the plant perimeter.
  • Unplanned release of more than 2 m3 uranium concentrate within secondary containment.
Record
  • Unplanned release of radioactive process materials, liquids or wastes, or more than 50 m3 into secondary containment or result in filling of more than 50% of secondary containment volume.
  • Release of more than 10 m3 of radioactive process materials, liquids or wastes beyond secondary containment, but contained within the engineered controls of the plant perimeter.
  • Unplanned release of mroe than 0.2 m3 of uranium concentrate within secondary containment.

TRS, corridors and pipelines

Report
  • Unplanned release of more than 50 m3 radioactive process materials, liquids or wastes within TRS bunded areas and pipeline corridors.
  • Unexpected degradation or defect in the TRS or evidence of leakage from Evaporation Ponds or Storage Ponds that, unless remedied, is likely to lead to a reportable release of radioactive process materials, liquids or wastes.
Record
  • Unplanned release of more than 10 m3 radioactive process materials, liquids or wastes within TRS bunded areas and pipeline corridors.
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Glossary of terms used

Report A verbal report in the first instance, followed by a written report by email or fax within 24 hours.
Record Details of the event are to be recorded in an operator's log or equivalent for inspection by regulators as necessary.
Radioactive substance As defined in the Radiation Protection and Control Act 1982.
Uranium concentrates Includes all concentrated uranium bearing solutions, slurries and solids from the feed to the uranium precipitation and thickening process, through to the final drummed product.
Operational areas Processing plant, tailings and evaporation ponds, ISR wellfields pipeline corridors and other areas approved by the regulators, which have clearly defined perimeters engineered to prevent the release of liquids from the site. The engineering controls may consist of bunds, drains, stormwater colelction points and ponds etc.
Undisturbed environment Refers to the areas outside the approved engineering controls (e.g. pipes, stormwater drains and ponds, bunding of the plant or wellfield or pipeline corridors, airborne emission control equipment or the wellfield mining zone).
Primary containment Refers to pipes, tanks and vessels and other engineered containment of radoactive process materials and solutions.
Secondary containment Refers to bunded process areas within the plant perimeter.
Wellfield mining zone Refers to the ISR ore zone, bounded by approved monitoring wells.
ISR mining fluid excursions

As defined in the operation's Environmental Management and Monitoring Plan.