Radiation & Other Operational Risk
Radiation risk is managed through, inter-alia the following:
- Annual Radiation Management Review Meetings
- Integrated Waste Management Programme
- Worker Radiation Protection Programme
- Public Radiation Protection Programme
- Transport Procedure
- Radiation Protection Function
- Physical Security Procedure
- Occurrence Reporting Procedure
- Quality Management Programme
- Medical Surveillance Programme
- Self-Inspection Programme
- Surface Workers Safety Assessment
- Underground Workers Safety Assessment
- Occurrence Reporting Mechanism
- Emergency Preparedness Programme
- Preliminary Decommissioning Plan and Strategy
Other operational risks are identified and mitigated when required but fundamentally the methodology followed entails, inter-alia the following:
Risk Assessment Method
The Safety Risk Management Process provides a basis for Workplace Risk Assessment and Control (WRAC) method. This method allows for functional as well as geographical assessments considering the energy sources involved.
Risk Analysis Method
The obscurity of the operations and interaction with machinery in the confined environment increase the change of a major event taking place and therefore necessitate the use of a qualitative approach for the Analysis, not only because of the lack of data for a quantitative analysis, but predominantly because of the conceivable impact involved.
The evaluation consists of three phases; likelihood estimation, Impact result and detect ability of the failure or trigger event. Risk importance is calculated by the product of the aforementioned.
The ALARP (As Low As Reasonably Practicable) test indicates the appropriate level of expenditure that should be incurred to reduce the risk and is intended to prevent inappropriate or excessive costs being incurred for risk control.
Mr ID Kruger is the owner of a privately owned company doing Consultancy work in Radiation Protection in the Nuclear Fuel Cycle, and particularly at mining and minerals processing operations. He is registered as a Professional Natural Scientist (Pr.Sci.Nat.) in the field of Radiation Science through the South African Council for Natural Scientific Professions (SACNASP). He is also recognised as a Radiation Protection Specialist by the National Nuclear Regulator, and certified as an ISO 9001 Management Systems Lead Auditor by the Southern African Auditor Training and Certification Authority (SAATCA).
Pierre has been involved with NORM since 2007. He qualified and was formally appointed as a Radiation Protection Officer (RPO) in 2010. He has experience in radiation safety, the workings with mines and processing facilities. Basic tasks as part of a team:
Maintaining and implementing Quality Control Systems that would include:
- Implementation of monitoring programs i.e. area and personal survey schedules, self-inspection schedules, medical surveillance schedules, etc.
- Updating and implementation of programs and procedures
- Dose reporting to NNR and DMRE on regular basis
- Occurrence reporting and management
- Waste reporting to NNR on regular basis
- Instrument maintenance and management
- Management reviews i.e. reporting to executive manager on radiation control status
Liezel has been working as a Radiation Protection Professional in the Heavy Minerals Mining Industry for the last 18 years and has a diverse skill set and a strong commitment to workplace radiation safety and compliance.
Assisting with maintaining and implementing Quality Control Systems that would include:
- Implementation of monitoring programs i.e. area and personal survey schedules, self-inspection schedules, medical surveillance schedules, etc.
- Updating and implementation of programs and procedures
- Dose reporting to NNR and DMRE on regular basis
- Occurrence reporting and management
- Waste reporting to NNR on regular basis
- Instrument maintenance and management
- Management reviews i.e. reporting to executive manager on radiation control status
The Radiation Team
SMM was issued COR23 Certificate of Registration by the NNR. One of the requirements of the COR is to have a radiation team available for maintaining and monitoring the effectiveness of radiation protection programmes and procedures. The Radiation Protection Team for SMM are in possession of all the required skills and training and have more than 50 year’s radiation management experience among themselves. The team consists of:
- The Executive Manager.
- The Radiation Protection Specialist.
- The Radiation Protection Officers.
- The Radiation Protection Monitors.
- The Appointed Medical Practitioner.
The team works closely together to manage radiation risk to employees and the public through the implementation of control programs covering radiation safety aspects like:
- Public safety,
- Worker safety,
- Transport safety, and
- Waste management.
The effectiveness of a Quality Management System and Control Measures are monitored through the implementation of monitoring and survey programmes. These cover areas within the authorised site, as well as some areas surrounding the operational site:
- Radiation exposures are measured, calculated and reported to the regulators.
- Information reported is checked and confirmed by regulators during site visits.
- Radiation awareness training is provided for employees and visitors.
- A fully implemented Medical Surveillance programme ensures that employee health is constantly monitored.
Pre-Startup Radiation Management to Current State
ACR – Submission and approval timeline per phase
All phases approximated from 15 January 2024
ACTIVITIES
- Appoint second permanent RPM – Surface
- Order balance of instruments to prepare for production phase
- Expand underground WSA – include production activities.
- Expand surface WSA – include production activities
- Reviewing suite of documents – include production activities
- Expand area and personal monitoring program while performing tasks as approved by NNR in Phase 0.
- Expanded sampling and monitoring programs – gather public monitoring data for public protection documents.
ACTIVITIES
-
PHASE 0:
Submitted pre-operational Plant Surface and Underground Worker Safety Assessments and suite of ACRs to NNR.All submitted – Awaiting NNR final approval
-
PHASE 1A:
Design, Construct, and Operations (Require NNR up front engineering input): Submit Plants Design to NNR Submit Mine Plans and Design to NNR Submit Prospective Surface and UG WSAs, and required procedures Submit Prospective PSA, and Public RPP Submit long term waste storage management strategy and Decommissioning plan and strategy.Mid December 2024 – Submit and await NNR comment and approval – 6-Months
-
PHASE 1B:
Commission new concentration plant, new cracking plant, rare earth elements separation plant, and commence with mining operations2025 – 2026 – Submit and await NNR comment and approval – 6-Months
-
PHASE 2:
Submit Confirmatory Operational Worker Safety and Public Safety Assessments and full suite of operational ACRs to NNR.2026-2028 – Submit and await NNR comment and approval – 6-Months
Extract of SMM – NNR Correspondence Register (CoR23)
2024 ACR Submissions Summary, Last Updated: 2024/08/15
