Worker Health

The Proposed Yellowhead Mine;

Worker Health Concerns

When we research the question of air pollutants, like radon, in Canadian mines there is much attention given to uranium mines and underground mines but, due to particular assumptions that have little in the way of scientific evidence, open pit mines appear to have been given a free pass with few questions being asked. In Canada, this is called the “3.3.1 Unrestricted Classification” (1,2) which appears to evade such rudimentary observations like data gathering and reporting.

1) “3.3.1 Unrestricted Classification

Where the estimated incremental annual effective dose to the public is less than 0.3 mSv/a and to the worker is less than 1.0 mSv/a, the NORM program classification is Unrestricted. No further action is needed to control doses or materials. “ (2)

It is possible that this classification evolved from a rather incomplete international survey;

“Unlike in uranium mines, radon exposure in non-uranium mines is normally not under

regulatory control. Continuous monitoring and control of the radiation exposure levels of workers is not undertaken in conventional mines in many countries since, as reported by the United Nations Scientific Committee on the Effects of Atomic Radiation (^{UNSCEAR 2022}), exposure data for non-uranium miners are very limited. For the period 2005–2009, the UNSCEAR Global Survey of Occupational Radiation Exposure only received detailed exposure data for non-uranium mining operations from four countries out of 57 United Nations member states that expressed interest in participating in the survey. “(2)

There is a very large variety of open pit mines and these can vary in many ways. NTWatch would like to express its profound caution with regard to the proposed Yellowhead Mine which appears to have several factors that distinguish it insofar as the potential for radon gas and its impact on the health of the human lung.

1. Tailings piles from any open pit mine will emit radon gas. It doesn’t have to be a uranium mine. The Austrian Radon Project (referenced in our second submission) shows that excessive radon can be emitted from something as normal as a landslide and that this will cause excessive radon exposure in low lying areas nearby. NTW presented this in its second comment regarding the Yellowhead project. Further to this, a South African study associated an excess of radon coming from abandoned gold mine tailings. (4). Other studies have discovered excessive radon coming from copper, and other types of mine tailings.

2. Excessive radon can also be present when there is fluorite content in the rock (6). Fluorite has been mapped in the area close to the proposed Yellowhead site. See references in our second submission.

3. Scattered bits of uranium have been mapped on the plateau throughout the area where the Yellowhead mine might be. This would increase the potential for radon gas emissions.

4. Given its heavy molecular weight relative to other atmospheric gasses, radon will always have a tendency to seek out low lying areas, such as at the bottom of an open pit mine. Although this may be mitigated by particular atmospheric conditions and the actual configuration of the mine, this tendency should be accepted as the normal state of affairs.

5. Radon is water soluble (5) and it may already exist in the groundwater at the proposed site. Radon from the tailings would also enter water runoff that would collect at the bottom of the open pit. It is very noteworthy that water-borne radon is now recognized as the cause of many premature deaths in the fluorespar mine at St. Lawrence, Newfoundland. This mine was underground and although it was NOT a uranium mine, it was ventilated. Yet many miners died prematurely because of exposure to radon and other contaminants. (7) We realize that the St. Lawrence mine and the proposed Yellowhead Mine are quite different but we would like to emphasize the potential for water-borne radon accumulating in the bottom of the pit.

Given the above reasons which are supported by the literature we have referenced, we believe that the Yellowhead mine would pose an excessive risk to individuals working there. We are also greatly concerned by the “free pass” that open pit, non-uranium mines have been given in BC and in Canada. Many of the risks and outcomes can be assessed beforehand, superficially at least. We have attempted to look at the potential for radon accumulation, insofar as the case of the Yellowhead Mine proposal is concerned.

A lot of work needs to be done on the subject of open pit mines, in BC, and how their various airborne contaminants relate to the particular geologies of the sites. As well, before any of these mine proposals is fast tracked, an investigation of the health impact of open pit mines on their employees, past and present, should be launched and the results correlated with the above factors.

In conclusion, we believe that we have presented additional reasons why this mine proposal should be rejected.

TWatch

References;

1.https://journals.lww.com/health-physics/fulltext/2023/04000/a_review_of_radon_exposure_in_non_uranium.2.aspx

2. https://www.canada.ca/en/health-canada/services/publications/health-risks-safety/canadian-guidelines-management-naturally-occurring-radioactive-materials.html#a1.4.1

3. https://dergipark.org.tr/en/download/article-file/3563208

4. https://www.frontiersin.org/journals/public-health/articles/10.3389/fpubh.2024.1328955/full

5. https://www.frontiersin.org/journals/public-health/articles/10.3389/fpubh.2024.1328955

6. https://link.springer.com/journal/41207 (https://link.springer.com/journal/41207)

7. h (https://www.cnsc-ccsn.gch.ca/eng/resources/health/health-studies/radon-progeny-exposure-and-lung-cancer-mortality-study-newfoundland-fluorspar-miners/)ttps://www.cnsc-ccsn.gch.ca/eng/resources/health/health-studies/radon-progeny-exposure-and-lung-cancer-mortality-study-newfoundland-fluorspar-miners/ (https://www.cnsc-ccsn.gch.ca/eng/resources/health/health-studies/radon-progeny-exposure-and-lung-cancer-mortality-study-newfoundland-fluorspar-miners/)