AREVA Resources Canada Inc. (ARC) is headquartered in Saskatoon, Saskatchewan. ARC is part of AREVA’s Mining Business Group which conducts the activities of exploration, extraction and processing of uranium ore, as well as site reclaimation and post-closure monitoring. The Mining Business Group holds a portfolio of mines in operation in Canada, Kazakhstan and Niger, as well as several projects under development.
AREVA appreciates the opportunity to provide comments on the draft ICRP document, “Radiological Protection against Radon Exposure”. We have been collaborating with our mining industry colleagues through the WNA Working Group on Uranium Mining Standardization and support the comments submitted to the ICRP by Mr. Jamie Townes (WNA). We offer the following few comments.
G1: Smoking is by far the leading cause of lung cancer. The ICRP document must place radiological protection against radon exposure in context with the lung cancer risk from smoking. The comments submitted to ICRP by Dr. Doug Chambers (SENES) at the request of the Working Party of the Main Commission provide the appropriate context.
G2: The document requires a thorough technical edit before it is published. A second round of consultation following revision and integration of comments is likely warranted.
S1: In Section 4, a subsection has been included to address radiological protection of workers in uranium mining. The information presented is a partial elaboration of bulleted points made in the previous subsection as applied to uranium mining. In this context, uranium mining is being used as a singular example of controlling occupational exposure. It is not the only one. Uranium mining should be presented as a subsection to section 4.2 and, for a balanced presentation, examples also included for other occupational exposure situations including other NORM industries.
S2: Para 171 – The second paragraph related to dose conversion does not apply solely uranium mining; it should be placed in a general section, if included at all. Though the ICRP has stated its intentions to address dose conversion through biokinetic and dosimetric modeling, their remains uncertainty within the radiation protection community as to whether the move to the dosimetric approach is premature, the models are properly validated, and they are able to adequately account for confounding factors such as smoking. Further, there remains uncertainty about whether applying the dosimetric approach is the right thing to do at this time given the increased coherence in epidemiological evidence from miner and residential studies and the acceptance and understanding of the epidemiological approach in the industry. It is not necessary for this document to address the current uncertain status of the future of dose conversion for radon progeny exposure. The paragraph could be dropped without consequence to the document.
Thank you for the opportunity to participate in the consultation process.
Safety, Health, Environment and Quality
AREVA Resources Canada Inc.