Appendix C

World Nuclear Association Basic Principles

The following material is taken verbatim from a World Nuclear Association (WNA) policy document “Sustaining Global Best Practices in Uranium Mining and Processing—Principles for Managing Radiation, Health and Safety, Waste and the Environment.”1 The WNA is an international organization with the goal of promoting nuclear energy and a mission to seek to foster interaction among top industry leaders to help shape the future of nuclear power.

PRINCIPLE 1: ADHERENCE TO SUSTAINABLE DEVELOPMENT

Conduct all aspects of uranium mining and processing with full adherence to the principles of sustainable development as set forth by the International Council on Mining and Metals. Apply these principles with emphasis on excellence in professional skills, transparency in operations, accountability of management, and an overarching recognition of the congruency of good business and sound environmental practices.

Discussion: In establishing its sustainable development principles, the ICMM adopted the landmark definition of that term advanced by the Brundtland Commission: “Development that meets the needs of the present without compromising the ability of future generations to meet their own needs.” To this the ICMM added: “In the mining and metals sector … investments should be financially profitable, technically appropriate, environmentally sound and socially responsible.”

In emphasizing the practical necessity of financial profitability, the ICMM underscored that economic profitability and sustainable development, far from

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1 See http://www.world-nuclear.org; accessed October 2011.



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Appendix C World Nuclear Association Basic Principles T he following material is taken verbatim from a World Nuclear Association (WNA) policy document “Sustaining Global Best Practices in Uranium Mining and Processing—Principles for Managing Radiation, Health and Safety, Waste and the Environment.”1 The WNA is an international organization with the goal of promoting nuclear energy and a mission to seek to foster interac- tion among top industry leaders to help shape the future of nuclear power. PRINCIPLE 1: ADHERENCE TO SUSTAINABLE DEVELOPMENT Conduct all aspects of uranium mining and processing with full adherence to the principles of sustainable development as set forth by the International Council on Mining and Metals. Apply these principles with emphasis on excellence in professional skills, transparency in operations, accountability of management, and an overarching recognition of the congruency of good business and sound environmental practices. Discussion: In establishing its sustainable development principles, the ICMM adopted the landmark definition of that term advanced by the Brundtland Commis- sion: “Development that meets the needs of the present without compromising the ability of future generations to meet their own needs.” To this the ICMM added: “In the mining and metals sector . . . investments should be financially profitable, technically appropriate, environmentally sound and socially responsible.” In emphasizing the practical necessity of financial profitability, the ICMM underscored that economic profitability and sustainable development, far from 1 See http://www.world-nuclear.org; accessed October 2011. 324

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325 APPENDIX C being at odds, must be consistent and reinforcing goals. This congruency of purpose is reflected in the ICMM commitment to “seek continual improvement in performance and contribution to sustainable development so as to enhance shareholder values.” PRINCIPLE 2: HEALTH, SAFETY AND ENVIRONMENTAL PROTECTION In all management practices, ensure adequate protection of employees, con - tractors, communities, the general public, and the environment, as follows: Mining Safety—Ensure safe, well maintained site conditions for the protec- tion of employees and the public from all conventional mining hazards, including those related to airborne contaminants, ground stability and structure, geological and hydro-geological conditions, storage and handling of explosives, mine flood - ing, mobile and stationary equipment, ingress and egress, and fire. Radiation Safety—Comply with the principles of Justification, Optimization and Limitation, as follows: Justification: Authorize the introduction of any new practice involving radia- tion exposure, or the introduction of a new source of radiation exposure within a practice, only if the practice can be justified as producing sufficient benefit to the exposed individuals or to society to offset any potential radiation harm. Optimization and Limitation: Optimize radiation exposure to as low as reason- ably achievable, taking into account all socio-economic factors. Ensure compliance with the occupational and public dose limits laid down by the appropriate national and international regulatory and advisory bodies. In so doing, classify, according to risk, site personnel and work areas that are subject to radiation exposure. Plan and carefully monitor employee and contractor doses, radioactive discharges and emissions as well as resulting environmental concentrations and exposure rates. Estimate potential radiological impacts on the public and the environment. Personal Protective Equipment—Ensure that employees and visitors are provided personal protective equipment (PPE) appropriate for the hazard being controlled and compliant with relevant standards or specifications to control exposure to safe levels. Ensure that relevant personnel remain properly trained on the use and maintenance of this equipment. Ventilation—Ensure that workplaces are adequately ventilated and that air- borne contaminants are minimized in workplaces. Pay particular attention to controlling radon and related radiation exposures in uranium mines and process - ing facilities. Water Quality—Develop and implement site-specific water management practices that meet defined water-quality objectives for surface and ground waters (focusing particular attention on potable water supplies). Subject water-quality objectives to periodic review to ensure that people and the environment remain protected.

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326 APPENDIX C Environmental Protection—Overall, avoid the pollution of water, soil and air; optimize the use of natural resources and energy; and minimize any impact from the site and its activities on people and the environment. In so doing, include considerations of sustainability, bio-diversity and ecology in guarding against environmental impact. PRINCIPLE 3: COMPLIANCE Support the establishment of a suitable legal framework and relevant infra- structure for the management and control of radiation, occupational and pub - lic health and safety, waste and the environment. Ensure that all activities are authorized by relevant authorities and conducted in full compliance with appli - cable conventions, laws, regulations and requirements, including in particular the Safety Standard Principles of the International Atomic Energy Agency (IAEA). Do so with careful consideration to the applicable IAEA Safety Standards. In recognition that effective interaction of operators (including contractors) and the appropriate regulatory authorities is essential to safety, ensure that operators and contractors are licensed, having met the requirement of relevant authorities. PRINCIPLE 4: SOCIAL RESPONSIBILITY At all stages of uranium mining and processing, properly inform—and seek, gain, and maintain support from—all potentially affected stakeholders, includ - ing employees, contractors, host communities, and the general public. Establish an open dialogue with affected stakeholders, carefully consider their views, and provide feedback as to how their concerns are addressed. (See the WNA Charter of Ethics in Annex 1 and, in Principle 6 herein, the text on Environmental Impact Assessment.) PRINCIPLE 5: MANAGEMENT OF HAZARDOUS MATERIALS Manage and dispose of all hazardous materials (radioactive or non- radioactive)—including products, residues, wastes and contaminated materials— in a manner that is safe, secure and compliant with laws and regulations. Management of Hazardous Wastes and Contaminated Materials Act sys- tematically to establish and implement controls to minimize risks from such wastes and contaminated materials. Take actions to maintain and treat sources of hazardous materials on-site wherever it is practicable to do so. Control and minimize any releases into the environment, using carefully planned strategies that involve pollution control technologies, robust environmental monitoring, and predictive modelling to ensure that people and the environment remain well protected. Rely where possible on proven, best available, industry-scale technolo- gies. Focus particular attention on managing ore stockpiles and such potentially

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327 APPENDIX C significant sources of contamination as waste rock, tailings, and contaminated water or soils. With tailings, concentrate special effort on the design and con - struction of impoundments and dams and on the application of a recognized tail - ings management system for operations, monitoring, maintenance, and closure planning. Use risk analysis and controls to account for current and long-term stability of waste repositories and containment. As an integral aspect of mining and processing, characterize ore and waste rock. Consider the geochemistry and assess the risk of acid rock drainage (ARD); where ARD could occur, develop an ARD management plan which accounts for ARD-producing ore, reject materials and gangue, and which provides for appropriate scheduling of mining, stockpile segregation, processing and contaminant containment. Use effective containment designs to ensure against long-term liability from ARD-producing rock. Use all opportunities to reduce the creation of hazardous wastes and contaminated materials. To the extent practicable, recover, recycle and re-use such wastes and materials, regarding waste disposal as a last-resort option. From each site, control the release or removal of wastes and contaminated materials, using a chain-of- custody approach where needed. Safely manage all off-site streams for hazardous materials and contaminated wastes. PRINCIPLE 6: QUALITY MANAGEMENT SYSTEM Employ a recognized quality management system—including the quality- assurance steps of Plan, Do, Check and Act (PDCA)—in administering the management of all activities pertinent to radiation, health and safety, waste and the environment. Planning—At all development and operational stages, plan for the manage- ment of radiation, health and safety, waste and the environment. With the constant goal of avoiding risk and optimizing the use of natural resources and energy, update such plans regularly, and particularly in response to any significant change in activities or site conditions. Include, as a central element in such plans, steps for the control of emergencies and unplanned events. Ensure that plans are well documented and communicated. In developing a uranium mining or processing project, prepare a formal Environmental Impact Assessment (EIA) that deals with all questions and concerns related to radiation, occupational and public health and safety, waste and the environment, as well as socio-economic impact. Submit the EIA as part of the public review process so as to provide response opportunities for stakeholders, especially the workforce and host communities. During the life of a project, prepare further EIAs if and as warranted by new circumstances. Risk Management—Apply risk assessment and management procedures to radiation, occupational and public health and safety, waste and the environment. Identify, characterize and assess all risks that can impact on health, safety and environmental protection. Mitigate risks with controls in engineering, admin - istration and other protective measures. Apply a hierarchy of risks and con -

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328 APPENDIX C trols. Monitor risks and take timely action to offset the emergence of new risks. Regularly review performance to improve procedures, further reduce risk, detect weaknesses and trigger corrective measures. Document and report relevant data, and maintain records in compliance with regulatory requirements. Place special emphasis on data required and acquired by the quality assurance management system. PRINCIPLE 7: ACCIDENTS AND EMERGENCIES Identify, characterize and assess the potential for incidents and accidents, and apply controls to minimize the likelihood of occurrence. Develop, imple- ment and periodically test emergency preparedness and response plans. Ensure the availability of mechanisms for reporting and investigating all incidents and accidents so as to identify “root cause” and facilitate corrective actions. PRINCIPLE 8: TRANSPORT OF HAZARDOUS MATERIALS Package and transport all hazardous materials (radioactive and non- radioactive)—including products, residues, wastes, and contaminated mate- rials—safely, securely, and in compliance with laws and regulations. With radioactive materials, adhere to IAEA Regulations for the Safe Transport of Radioactive Material, relevant IAEA Safety Guides, applicable international conventions, and local legislation. PRINCIPLE 9: SYSTEMATIC APPROACH TO TRAINING In each area of risk, provide systematic training to all site personnel (employ- ees and contractors) to ensure competence and qualification; include in such training the handling of non-routine responsibilities. Extend such training, where appropriate, to visitors and relevant persons in communities potentially affected by these risks. Regularly review and update this training. PRINCIPLE 10: SECURITY OF SEALED RADIOACTIVE SOURCES AND NUCLEAR SUBSTANCES Ensure the security of sealed radioactive sources and nuclear substances, using the chain-of-custody approach where practicable and effective. Comply with applicable laws, international conventions and treaties, and agreements entered into with stakeholders on the safety and security of such sources and substances.

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329 APPENDIX C PRINCIPLE 11: DECOMMISSIONING AND SITE CLOSURE In designing any installation, plan for future site decommissioning, remedia - tion, closure and land re-use as an integral and necessary part of original project development. In such design and in facility operations, seek to maximize the use of remedial actions concurrent with production. Ensure that the long-term plan includes socio-economic considerations, including the welfare of workers and host communities, and clear provisions for the accumulation of resources adequate to implement the plan. Periodically review and update the plan in light of new circumstances and in consultation with affected stakeholders. In connec - tion with the cessation of operations, establish a decommissioning organization to implement the plan and safely restore the site for re-use to the fullest extent practicable. Engage in no activities—or acts of omission—that could result in the abandonment of a site without plans and resources for full and effective decom - missioning or that would pose a burden or threat to future generations.