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10th - July- 2007 | KEYNOTE ADDRESS BY PROF. ANTHONY O. ADEGBULUGBE FORMER SPECIAL ADVISER TO THE PRESIDENT ON ENERGY

It is my pleasure and privilege to join the Director General/Chief Executive of the Nigerian Nuclear Regulatory Authority in welcoming you to this Stakeholders Forum. I feel honoured to address this very distinguished audience at this Forum to deliberate on the issue of radioactive waste arising from tin mining activities on the Jos Plateau, which is the first of its kind.

Your Excellency, the Special Guest of Honour, Distinguished Ladies and Gentlemen

Let me take you back to history. Tin mining was discovered around 1700-­1750 in Kuza near a river channel, Jos. During this time of subsistence agriculture, the people needed more advanced tools besides their hands and sticks. The farmers saw tin minerals and crystals near the river. They realized by mixing tin and iron, they could have stronger agricultural instruments. The people believed the discovery of tin was a gift of god.

By 1760-1770, there were thirteen indigenous blacksmith smelters in Naraguta, located just north of Jos. The Biron ethnic group were finding and producing tin along the Delimi River near Jos.

Tin became popular during the industrial revolution in Europe. Spain was using the tin for gun barrels and during the First World War the need for tin increased for the use of ammunition.

By 1913, there were one hundred and eight (108) mining companies registered by the Royal Niger Company. By 1943, tin mining on the Jos Plateau was at its peak. There were 80,000 African workers. Up to 1960, Jos was the sixth largest producer of tin in the world. Two hundred twenty-five

kilometers of land was taken out by tin mining. This is only 4% of the plateau, which is in the valleys. In the 1970s Nigeria produced an average of 10,000 tons of tin ore annually. Experts estimate miners on the Plateau dig up six million tons of soil each year.

Sitting on a vast, mineral-rich plateau, Jos and its surrounding areas became prosperous and famous as a result of tin mining activities. But the area's wealth has come at a price for locals, as tin mining has gradually destroyed much of the surrounding country.

Many locals complain that decades of tin mining have left them a legacy of polluted water supplies, impoverished land and even radioactive waste. In places on the Plateau such as Bukuru, Rayfield, Shere Hills and Anglo-Jos, ugly gullies left over from past mining activities can be seen everywhere. Alarmingly, effluents from nearby industries have seeped deep into mines­turned-water holes. These are used by farmers to irrigate their fields. The top soil also washes into streams in neighbouring villages - water that is used for drinking and other domestic purposes. Also at risk of being contaminated is the underground water in the area. In addition, locals use soil left over from the abandoned mining sites - containing naturally-found radioactive heavy metals - to build houses. Environmentalists fear that people living in these houses risk being exposed to unhealthy levels of radiation.

For 67 years Jos' tin mining industry was mostly controlled by overseas companies. But when the industry was nationalized in 1972, no one took responsibility for clearing up the mess left behind. Thirty six years on, little appears to have changed. Environmental activists believe it is true that the cost of closing all the abandoned mines and cleaning up polluted streams and rivers is beyond their (miners) means.

"Your Excellency, the Special Guest of Honour, Distinguished Ladies and Gentlemen
Naturally occurring radioactive material (NORM) is distributed throughout the earth's crust and contains nuclides. These nuclides give rise to "background" radiation, which varies by two orders of magnitude over the earth's surface. The widespread occurrence of NORM means that many of the ores and minerals and oil and gas used by humans can contain NORM. When the NORM concentrations have been modified in the material, it is called technologically enhanced naturally occurring radioactive material, or TENORM. Human health is not affected in the majority of these situations, as the activity arising from the NORM levels is not very high. However, when NORM has been significantly concentrated through large-scale industrial production as is the case of tin mining activities on the Jos plateau, occupational and public exposure to radiation can become an issue. In some countries this is already being addressed, but in Nigeria NORM has not been addressed properly. Hence, this forum came at a good time.

Lack of awareness of radioactive waste from NORM in the past has led to the creation of contaminated sites for which no individual or organization is legally accountable. The remediation of these sites will require careful consideration.

The mining sector is a major source of radioactive waste that deserves urgent intervention. The tin mining activities around the Jos Plateau left behind a considerable amount of radioactive waste in the tin-mine tailings. The Jos plateau in central Nigeria is a high radiation area, being the centre of the unique granitic alkaline ring complexes that are rich in accessory
Your Excellency, the Special Guest of Honour, Distinguished Ladies and Gentlemen
Naturally occurring radioactive material (NORM) is distributed throughout the earth's crust and contains nuclides. These nuclides give rise to "background" radiation, which varies by two orders of magnitude over the earth's surface. The widespread occurrence of NORM means that many of the ores and minerals and oil and gas used by humans can contain NORM.
When the NORM concentrations have been modified in the material, it is called technologically enhanced naturally occurring radioactive material, or TENORM. Human health is not affected in the majority of these situations, as the activity arising from the NORM levels is not very high. However, when NORM has been significantly concentrated through large-scale industrial production as is the case of tin mining activities on the Jos plateau, occupational and public exposure to radiation can become an issue. In some countries this is already being addressed, but in Nigeria NORM has not been addressed properly. Hence, this forum came at a good time.

Lack of awareness of radioactive waste from NORM in the past has led to the creation of contaminated sites for which no individual or organization is legally accountable. The remediation of these sites will require careful consideration.

The mining sector is a major source of radioactive waste that deserves urgent intervention. The tin mining activities around the Jos Plateau left
behind a considerable amount of radioactive waste in the tin-mine tailings. The )05 plateau in central Nigeria is a high radiation area, being the centre of the unique granitic alkaline ring complexes that are rich in accessory

minerals of zircon, monazite, ilmenite, xenotime, thorite and pyrochlore which contain high concentrations of thorium and uranium.

Your Excellency, the Special Guest of Honour, Distinguished Ladies and Gentlemen
The application of radiation sources and use of ores and minerals associated with radioactive materials and the concomitant generation of waste from the usage have been going on in Nigeria for several decades. But the systematic development of the peaceful applications of nuclear energy in Nigeria commenced with the promulgation of the Nigeria Atomic Energy Commission (NAEC) Decree 46 of 1976. In Nigeria, peaceful applications of nuclear energy can be found in the health sector, the petroleum industry, mining industry, industrial sector, agriculture and education and research.

In August 1995, the Federal Government promulgated the Nuclear Safety and Radiation Protection Decree 19 (now Act 19 of 1995 [Act]), but not implemented until February 2001, when President Olusegun Obasanjo established the Nigerian Nuclear Regulatory Authority (NNRA. The NNRA has the overall responsibility for nuclear safety and radiological protection regulation in the country. The Act empowers the NNRA to amongst others, "regulate the possession and application of radioactive substances and devices emitting ionizing radiation" in the country.

The Authority has the responsibility for regulating the possession and application of radioactive substances and devices emitting ionizing radiation; ensuring protection of life, health, property and the environment from the harmful effects of ionizing radiation, while allowing beneficial practices involving exposure to ionizing radiation. By so doing, the NNRA regulates the introduction of radioactive sources, equipment or practices and of existing sources, equipment and practices involving exposure of workers and the
general public to ionizing radiation.

The Act empowers the NNRA to categorize and license activities involving exposure to ionizing radiation, in particular, the possession, production, processing, manufacture, purchase, sale, import, export, handling, use, transformation, transfer, trading, assignment, transport, storage and disposal of any radioactive material, nuclear material, radioactive waste, prescribed substance and any apparatus emitting ionizing radiation. Furthermore, the NNRA is also charged with the responsibility for regulating as appropriate, the exploration, mining and milling of radioactive ores and other ores associated with the presence of radioactive substances.

Your Excellencv, the Special Guest of Honour, Distinguished ladies and Gentlemen
The NNRA since its inception under the able leadership of Professor S. B. Elegba, a distinguished Professor of international repute has been doing a great job in carrying out its mandate as enshrined in Act.

A major part of radiological protection is the problem of public exposure arising from past activities of mineral exploration and exploitation in the mining and oil sectors. The NNRA takes the case of natural radioactive waste from these sources as special case. NORM is a radioactive waste, which must be properly disposed to minimize exposure to workers and members of the general public. Ionizing radiation is harmful, be it from radioactive sources or from radioactive waste!

As part of its efforts in ensuring radiological protection in general, and public exposure control in particular, the NNRA set up a Technical Advisory Committee (TAC) in 2004 to consider the sources of Radioactive Waste in
the country. In its report, the TAC established that there were several hundreds of thousands of Tonnes of Radioactive Waste, which had been accumulated on the Jos Plateau as a result of tin mining activities which produces mine tailings. The TAC also established the accumulation of Radioactive Waste in the petroleum industry in the form of scales, sludge, etc. These types of Radioactive Wastes are generally referred to as Naturally Occurring Radioactive Material (NORM). Using the report of this Committee, the NNRA went further to draft national regulations for the management of NORM Radioactive Waste.

In an effort to generate input from stakeholders on the draft regulations, the NNRA held the National Training Workshop on Radioactive Waste Management: Policy, Regulations and Practice in March 2006. Part of the communique of the Workshop was that the NNRA be responsible (as required by the Act) for the management of the NORM waste in the mined areas of the Jos Plateau and the oil exploitation areas of the Niger Delta.

In addition, toward the end of 2006 the NNRA launched the Radioactive Waste Management Regulations 2006 in continuation of its efforts at achieving its mandate in ensuring radiological safety in the country

Your Excellency, the Special Guest of Honour, Distinguished Ladies and Gentlemen

Not too far from here at the National Veterinary Research Institute, Vom there are high-risk Caesium 137 and the Cobalt-50 radioactive sources. These were part of the now abandoned Biological Control of Tsetse Flies (BICOT) Project in Vom, Plateau State. This is a project under the Federal Ministry of Agriculture supported by the International Atomic Energy Agency (IAEA), Vienna, Austria for the sole purpose of eradicating tsetse flies which afflict livestock and man with sleeping sickness. Due to lack of funds, the project was abandoned without making arrangement for the evacuation and disposal of radioactive sources. Besides the abandonment of the project, the building that housed the sources was completely destroyed in a fire incident, thus heightening the issues of the safety and security of the sources in 2002. The NNRA has since taken over the site. These sources now constitute radioactive waste. It was only this year that the IAEA with its own resources, graciously accepted to evacuate them from the country and get them disposed appropriately. As we speak here today, this project is being executed by the NNRA in collaboration with the IAEA, NECSA of South Africa, MSD Nordion of Canada. This collation has commenced the evacuation and repatriation of this and other radioactive waste from the country. The exercise involves not only the radioactive waste in Vom but also those from Lagos and Ibadan. This is a major security exercise involving all the security organisations in the country. Imported radioactive sources are however not the only source of radioactive waste generated in the country.

Your Excellency, the Special Guest of Honour, Distinguished Ladies and Gentlemen
In response to the NORM situation in the country, the Presidency in collaboration with the NNRA appointed some consultants in December 2006 to carry out a survey of the tin-mine tailings on the Jos Plateau and recommend ways of ameliorating its impact on the workers and the public. The observations and lessons from the survey showed that there was need to address the issue of radioactive waste in the mining industry in general. These included the issues of responsibility for the Radioactive Waste generated and the responsibility for ameliorating/eliminating the health hazards associated with the Radioactive Waste on the public.

Of very serious concern is the several years of mining and processing of cassiterite (tin ore) and columbite (niobium ore) in the Jos plateau that have
generated large quantities of tailings that are rich in these radioactive
I minerals and are mostly dumped haphazardly in the environment. Radiation monitoring in the area and at some processing mills shows high levels of dose rate with values as high as 100 micro-Sievert per hour (100 ~lSv.h-1) for processed zircon. Elemental composition of these tailings shows high concentrations of uranium and thorium with values of up to 0.2wt% and 4wt% respectively. The in-situ dose rate measurements for public and worker exposures are significantly higher than the recommended values of 1 mille Sievert (1.0 mSv) and 20 mille Sievert (mSv) per annum respectively. The fact that the mine tailings are also used by the villagers for plastering their mud houses; and by the elite for the lining of golf courses, tennis lawns, etc, such a situation calls an urgent regulatory concern, particularly for the Federal and the Plateau State governments.

I am aware that the NNRA has since the survey of 2004 developed regulatory framework for the management of radioactive waste, the consideration of which I believe is part of the objectives of this Forum. In this regard, the NNRA has developed a Radioactive Waste Management Policy and Strategy, which will serve as a national commitment to address the country's radioactive waste issues in a co-ordinated and sustainable manner. It envisages that the management of radioactive waste in Nigeria shall be in accordance with national objectives and recognized international principles as set out in the Policy. The NNRA has in 2006 gazetted the Nigerian Radioactive Waste Management Regulations. The NNRA also developed draft regulations for the Management of Radioactive Waste arising from Technologically Enhanced Naturally Occurring Radioactive Material (TE­NORM). These together with the policy will be exhaustively discussed at this Foru m.

Your Excellency, the Chairman, Distinguished Ladies and Gentlemen
From the forgoing, we have been able to highlight the challenges facing the country vis-a-vis radioactive waste management in the country. But do we have international obligations and even rights with regards to the management of radioactive waste. You will all recall that in 1980s, there were several attempts to dump radioactive waste in West Africa and in fact industrial waste was actually dumped in Koko, Nigeria in 1987. As a result of these, incidents, Nigeria championed the call for an international ban on waste dumping across international borders. These efforts resulted in the Bamako Convention, to which Nigeria is a party. The requirements for

radioactive waste and spent nuclear fuel are more stringent. Nigeria presently operates a Nuclear Research Reactor and imports a couple of thousands of radioactive sources annually. These sources when they are no longer useful and the spent nuclear fuel in the reactor must be exported out of the country for appropriate disposal. It is pertinent at this point to emphasize that there is no radioactive waste disposal facility in the country. Movement of this category of waste is governed by the Joint Convention on the Safety of Spent Fuel Management and Radioactive Waste Management, which was" negotiated under the IAEA and adopted in 1997 by a Diplomatic Conference convened by the IAEA. The Joint Convention (JC) was opened for signature in 1997 and entered into force in 2001. Nigeria only in March 2007 became party to this Convention.

The case for signing this Joint Convention has been accentuated by Chief Olusegun Obasanjo, the former President of the Federal Republic of Nigeria, when he invited the IAEA to partner with Nigeria to generate electricity from nuclear power plants, against the backdrop of inadequate power supply (4000 Mega Watts of electricity) to Nigeria. The '4G' barrier of electricity generation has tormented the present administration since its inception and to increase the electricity generation over the next ten years to 25GW requires a big jump. This has further been emphasized by President Umaru Musa Yar'adua during his participation at the G-8 meeting, where he emphasized electricity, electricity and electricity as the priority of his administration.


Your Excellency, the Special Guest of Honour, Distinguished Ladies
and Gentlemen
The Contracting Parties to the JC amongst others recognize that the operation of nuclear reactors and other applications of nuclear technologies
generate spent fuel and radioactive waste and that the same safety objectives apply both to spent fuel and radioactive waste management. Parties therefore reaffirmed the importance to the international community of ensuring that sound practices are planned and implemented for the safety of spent fuel and radioactive waste management, amongst other things. Furthermore, desiring to promote an effective nuclear safety culture and radioactive waste management worldwide, the JC put the ultimate responsibility for ensuring the safety of spent fuel and radioactive waste management on the States through their regulatory authorities, in the case of Nigeria, the NNRA.
The objectives of the JC include the achievement and maintenance of a high level of safety worldwide in spent fuel and radioactive waste management, through the enhancement of national measures and international co­operation, including where appropriate, safety-related technical co­operation. Additionally, it is to ensure that during all stages of spent fuel and radioactive waste management there are effective defenses against potential hazards so that individuals, society and the environment are protected from harmful effects of ionizing radiation, now and in the future, in such a wa) that the needs and aspirations of the present generation are met withou compromising the ability of future generations to meet their needs anc aspirations. Furthermore, it is to prevent accidents with radiologica consequences and to mitigate their consequences should they occur during any stage of spent fuel or radioactive waste management.
Nigeria as a responsible player in the international community recognizes and identifies with such laudable efforts, especially with the requirements for trans-boundary movement of radioactive materials, including waste and, its obligations under the IAEA Illicit Trafficking in Nuclear and Radioactive Materials Database programme. We therefore need to give serious consideration to the JC with a view to signing and ratifying it.


Your Excellency, the Special Guest of Honour, Distinguished Ladies and Gentlemen
At this stage permit me to congratulate the NNRA for drawing the attention of governments at all levels (Federal, State and Local) to the two different types of waste. TE-NORM cont~ins low level concentrations but in large volumes compared to the radiation sources. The NNRA should also be appreciated for bringing to the public arena issues related to our international obligations in such an area as nuclear energy and the management of radioactive waste when we do not even have nuclear power plants. First time in Nigerian history that we have such a well laid regulatory body preparatory to the commencement of nuclear power generation.

I hope this Forum would bring concrete and practical suggestions on how to dispose of the NORM mine-tailings with minimal danger to the miners and the public. I wish you all fruitful deliberations.

Thank you for your attention and God Bless

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