Antinuclear

It is concerning that the uranium industry has used the expression “mild radiation” to describe its radiological environmental impacts, when there is no regulatory basis or definition to use this term, potentially giving the impression that the levels of radiation in the uranium mining industry are without risk to the environment. The evidence is clear and unassailable that this is not correct. Furthermore, it is appropriate that uranium mining continue to be considered a ‘nuclear action’ as specified by the EPBC Act as the radioactivity derives specifically from nuclear decay processes. Tailings from uranium mining are radioactive for millennia, resulting in unique environmental considerations for every uranium mine.

The International Commission on Radiological Protection has determined that the dose  coefficient for radon gas, one of the sources of radioactivity from uranium mining, needs to  be doubled, indicating that it is actually thought to be double the previously estimated carcinogenic hazard.1. ARPANSA is currently in the process of revising dose estimates to  workers. It follows that risks to others is doubled and makes it even more essential appropriate mitigation strategies are introduced. It also follows that the environmental risk is also increased.

With regard to human exposure, all radiation regulatory frameworks around the world  support the concept of the ‘linear no threshold’ (LNT) model of carcinogenesis. As the US  appropriate mitigation strategies are introduced. It also follows that the environmental risk is also increased.

With regard to human exposure, all radiation regulatory frameworks around the world  support the concept of the ‘linear no threshold’ (LNT) model of carcinogenesis. As the US coefficient for radon gas, one of the sources of radioactivity from uranium mining, needs to be doubled, indicating that it is actually thought to be double the previously estimated carcinogenic hazard.1

. National Academy of Sciences, Biological Effects of Ionising Radiation VII (BEIR-VII) report (2006) summarised:“..the current scientific evidence is consistent with the hypothesis that, at the low doses of interest in this report, there is a linear dose-response relationship between exposure to ionizing radiation and the development of solid cancers in humans. It is unlikely that there is a threshold below which cancers are not induced…”

This concept is also supported by all radiation regulators, the International Atomic Energy Agency, the United Nations Scientific Committee for the valuation of the Effects of Atomic  Radiation (UNSCEAR) and many others. It follows that there is strong evidence that even at  low doses any additional radiation over background levels increases the risk of malignancies. It logically follows that there are thus risks to non-human biota and the  broader environment, even at low doses of radiation, or as the Australian Uranium Association would perhaps describe it, ‘mild radiation.’……

Given the clear human health and environmental risks of even low dose radiation exposure, it is entirely appropriate that uranium mining and milling remain within the definition of nuclear actions” in the EPBC Act .Internationally radiation regulation is increasing, as the risks to human health and the environment become more apparent. The international emphasis (by the IAEA) is increasingly to consider radiation an environmental (as opposed to just a human) hazard so  it is appropriate that uranium mining be subject to Commonwealth environmental legislation. There is no reason why uranium mining should be exempt from the remit of the EPBC Act.

In conclusion, the uranium mining industry produces radioactive materials that have impacts on both human health and environmental health. It is essential that appropriate environmental and human safeguards remain, and that uranium mining and milling remains within the definition of “nuclear actions” for the purposes of the EPBC Act. There is a clear need for federal oversight to ensure clear and consistent implementation of these measures …http://www.mapw.org.au/files/downloads/2013-04-Productivity-Commission-uranium-submission.pdf