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Submitted by Daniel Zavattiero, Minerals Council of Australia
   Commenting on behalf of the organisation
Document Dose Coefficients for Non-human Biota Environmentally Exposed to Radiation
 
Please find attached a submission on the draft report for consultation: Dose Coefficients for Non-human Biota Environmentally Exposed to Radiation.
Please feel free to contact me with any queries.
Kind regards,
Daniel Zavattiero


7 October 2016


International Commission for Radiological Protection (ICRP)


Submission to Draft Report for Consultation: Dose Coefficients for Non-human Biota Environmentally Exposed to Radiation



The Minerals Council of Australia (MCA) welcomes the opportunity to provide comment to the Draft Report for Consultation: Dose Coefficients for Non-human Biota Environmentally Exposed to Radiation (the Draft Report).

Relevance to Australia’s uranium industry


The MCA is the peak industry organisation representing Australia’s exploration, mining and minerals processing industry, nationally and internationally in their contribution to sustainable development and society.  MCA member companies represent more than 85 per cent of Australia’s annual minerals industry production and a higher share of minerals exports.


Uranium exploration, development and mining company members of the MCA meet regularly as the MCA Uranium Forum.  Members of the MCA Uranium Forum are focused on safely and responsibly exploring for, developing and producing uranium exclusively for peaceful uses; that is for the production of low emissions electricity, nuclear research, nuclear medicine and industrial applications.


Overview


The MCA recognises the level of work that has been undertaken to produce this draft report and notes its importance in fundamental and pure research. For the protection of flora and fauna from radiological impacts, the MCA notes that the original ICRP concept provided useful guidance relating to protection at the species level, but had significant shortcomings as a regulatory tool at the impact levels associated with uranium mining.


The overall observation of the draft report is that it is very complex and likely to be impractical at an operational level.  This makes it difficult for the practitioner who may be required to put it into practice.


The MCA also notes that generally the radiological risks from mining operations are very low in most situations and that adding additional levels of complexity may overemphasise the actual radiological risks, thereby diverting attention (and resources) from risks which might be of higher priority at any given particular mine site.


We note that the document leaves a number of areas unanswered. For example, table 2.1 identifies a number of dosimetric quantities where no information exists. This may present an opportunity for further pure research; however, the unintended consequence could further increase the complexity in an area where the risks are typically immeasurably low.  The MCA recognises the value in pure research and development of assessment models which are aimed at practical outcomes where a real threat is present.


The document also raises the question of the potential open ended nature of research in the area of protection of non-human biota.  With over two million named species on Earth, the risk is that research would continue with little practical benefit. The draft document extends the range and now covers ‘organisms with body masses in range from 1 mg to 103 kg’.  The MCA acknowledges it is impractical to cover some species, particularly those with body masses of less than 1 mg.  The MCA recommends that ICRP provides guidance and sets limits for the scope (including the range of species assessed) in the non-human biota area, to avoid the problem of diminishing practical returns associated with potentially endless additional pure research.


Recommendation


While the practical application of the draft report is not necessarily its main focus, the MCA recommends that attention be given to this important area. In particular, the MCA recommends that the ICRP consider including additional information in Section 1 of the report providing guidance into the practical application of its main findings.


To this end, the MCA would be willing to provide input to the ICRP and access to the extensive network of uranium operations radiation practitioners amongst its member companies.


Conclusion


The MCA appreciates the opportunity to provide these comments.


Should the ICRP require any further explanation of the issues raised in this submission, please do not hesitate to contact me at Daniel.zavattiero@minerals.org.au or 03 8614 1813.


Yours Sincerely


DANIEL ZAVATTIERO
EXECUTIVE DIRECTOR – URANIUM