international atomic energy agency the licensing of rw

International Atomic Energy Agency

THE LICENSING OF RW MANAGEMENT FACILITIES /

REGULATORY REVIEWS AND INSPECTIONS

Nadja Zeleznik

REGIONAL WORKSHOP ON DEVELOPMENT OF

NATIONAL POLICY AND STRATEGY FOR RADIOACTIVE

WASTE MANAGEMENT IN LINE WITH THE IAEA SAFETY

STANDARDS

Vienna, Austria

24-28, March 2014


Contents

• Legislative and regulatory framework for licensing

• Licensing process for RW facility (disposal)

• Licensing of CISF - example

• Regulatory supervision

• Conclusions

• Addition: WAC development - example

2 2


Regulatory framework

• The main act in the area of nuclear and radiation safety is the Act on Ionizing

Radiation Protection and Nuclear Safety, usually called „Atomic act“:

• General issues

• Performance of radiation activities

• Protection of human against ionizing radiation

• Radiation and nuclear safety

• Licensing process (issuing, extension, dispossession, cessation)

• Physical protection of nuclear matters and nuclear facilities

• Limitation of transfer of nuclear goods

• Surveillance of radiation conditions in environment

• Remediation of consequences of emergency events

• Reporting

• Data collections

• Funding and compensation

• Administrative tasks and inspection

• Penalties

• Based on this Act, 27 decrees and regulation adopted

3 3

International Atomic Energy Agency 4

SNSA and SRPA within the governmental structure


• Decree on activities involving radiation

• Decree on dose limits, radioactive contamination and

intervention levels

• Decree on the areas of limited use of space due to a

nuclear facility and the conditions of facility construction in

these areas

• Decree on safeguarding of nuclear materials

• Decree on the criteria for setting compensation level

payable for limited use of space within the area of a nuclear

facility

• Decree on checking the radioactivity of shipments of scrap

metal

Governmental Decrees


• Rules on the specialist council on radiation and nuclear safety

• Rules on the use of radiation sources and on activities involving

radiation

• Rules on authorized experts on radiation and nuclear safety

• Rules on providing qualification for workers in radiation and

nuclear facilities

• Rules on radiation and nuclear safety factors

• Rules on radioactive waste and spent fuel management

• Rules on operational safety of radiation or nuclear facilities

• Rules on radioactivity monitoring

• Rules on transboundary shipments of radioactive waste and

spent fuel

• Rules on the transboundary shipment of nuclear and radioactive

substances

Rules / Regulations of the SNSA


• Rules on functioning of the Expert Council for the issues of ionizing radiation

protection, radiological activities, and the use of radiation sources in human and

veterinary medicine

• Rules on the use of radiation sources and on activities involving radiation

• Rules on the requirements of using ionizing radiation sources in healthcare

• Rules on the method of keeping records of personal doses due to exposure to

ionizing radiation

• Rules on the requirements and methodology of dose assessment for the

radiation protection of the population and exposed workers

• Rules on health surveillance of exposed workers

• Rules on approving of experts performing professional tasks in the field of

ionizing radiation

• Rules on the obligations of the person carrying out a radiation practice and

person possessing a ionizing radiation source

• Rules on the use of potassium iodide

• Rules on the conditions to be met by primary health care centers for breast

Rules / Regulations of the SRPA


Administrative control for RW repository

• RW facility is according to Ionizing Radiation Protection and Nuclear Safety Act (Atomic act) characterized as nuclear facility

• Atomic act describes methods for obtaining permits and consensus for:

• facility (repository) siting

• construction,

• trial operation,

• operation,

• end of operation and decommissioning,

• facility (repository) closure.

8


Facility (repository) siting

• Initiative for siting: responsible ministry

• Repository operator prepares environmental report + special safety analysis report - SSAR

• Fundamental document: National Spatial Plan for RW Repository – NSP RWR

• NSP RWR is prepared by Spatial Planning Directorate, Ministry of Infrastructure and Spatial Planning (MISP) and Ministry of Agriculture and the Environment (MAE) and adopted by governmental decree – SITE SELECTED

• Role of SNSA:

• provides frame and content for SSAR

• gives opinion for Environmental report

• dose regulatory requirement is 0,3 mSv/year for long term Normal Evolution Scenario (NES)

9


Environmental impact report

• Regulating body (administrative authority): SNSA, Slovenian Environment Agency (SEA at MAE)

• Prior consent on nuclear and radiation safety

• Environmental protection consent (SEA)

• Key document: Environmental impact report (EIR)

• SNSA proposes subjects related to nuclear and radiation safety

• Content is described by SEA

10

Environmental protection consent and NSP

Idea for new

facility

EIA +SSA report

SSA content

start of

preparation for

NSP

Environmental

protection consent

(SEA)

NSP decree

(government)

Prior consent

on nuclear

and radiation

safety

EIA report

EIA content

proposition

Environmental

Impact

Assessment

(EIA) content

A

Operator SNSA MISP, MAE,

government

ER opinion

11


Construction permit

• Administrative bodies: Ministry of Agriculture and

Environment, SNSA

• SNSA consent

• Construction permit by Ministry of Agriculture and

the Environment

• Documentation:

• PROJECT DOCUMENTATION

• SAFETY REPORT (SR) : Content of SR

prescribed by Regulation, reference

documentation

12

From EIA to construction permit

Construction

consent and SR

approval+trial

operation

conditions

Information

about

conditions

Information

request

Authorised

expert

opinion

Safety report

Construction licence

application

Construction licence

Operator SNSA MAE

A

B 13


Trial operation

• Administrative bodies: Ministry of Agriculture and the

Environment, SNSA

• Trial operation consent (SNSA)

• Trial operation permit (Ministry of Agriculture and

the Environment)

• Usage permit (Ministry of Agriculture and the

Environment)

• Documentation:

• SAFETY REPORT (SR) and other supporting

documents

14

Construction and trial operation

Construction

Trial operation

consent and SR

approval Authorised

expert

opinion

Trial operation application

Safety Report

Operator SNSA

B

Trial operation

C

Permit

for trial operation

start

MAE

1. Technical

inspection

2. Technical

inspection

Operating permit

15


Operation

• Administrative body: SNSA

• Operation permit

• Documentation:


documents

16

Start of operation

Assessment Authorised expert

opinion

Operating permit

application

Safety Report

Authorised

expert opinion

Operating

licence

Aditional

information request

Operator SNSA

C

Operation

D 17


Repository closure

• Administrative body: SNSA

• Repository closure permit

• Documentation:


documents

18

Repository closure

Authorised

expert

opinion

End of operation

application Safety Report

End of operation

decision

Operator SNSA

D

Closure

Authorised

expert

opinion

Closure

application Safety Report

Closure permit

Repository becomes national infrastructure facility

19


Example - licencing of Central interim storage facility

• Central Interim Storage Facility (CISF) in operation from 1986, transfer to ARAO from 1999 on. No nuclear licence.

• Request from SNSA for refurbishment and for safety report in order to obtain nuclear licence.

• Thorough examination of situation:

• Some installations and systems were out-of-date,

• The inventory was poorly characterize and arranged,

• No suitable procedures and instructions.

• Project documentation for refurbishment of storage in 2001:

• renewal of electric installations,

• water supply and sewage system renovation,

• ventilation system replacement and improve,

• improvements of the fire protection and

• remediation of minor defects in the building.


CISF

• Only storage for LILW from medicine, industry and research activities

• Constructed in 1984 in the vicinity of capital Ljubljana inside Nuclear research centre

• Near surface concrete building, dimensions app. 10 x 25 x 3.6 m, 9 sections

• 85 m3 of LILW stored, with total activity of 3600 GBq


Situation in CISF, BRINJE, 1999


Administrative – licensing procedure

• Two parallel documents: Safety Report for CISF based on project documentation and Environmental Impact Assessment.

• Licensing procedure:

• Construction license:

• consents from Slovenian nuclear safety administration, Health and fire inspectorate, Environmental agency, Slovenian radiation protection administration.

• Permit issued by Ministry of environment and spatial planning, Section for construction of national importance in 2003.

• Trial license: SNSA, SRPA (consent), MESP (permit) in 2005, includes the results of construction and tests.

• License for normal operation: SRPA (consent), SNSA (permit) + MESP (permit) in 2008, incorporates the results of improvements during trial operation.

RECONSTRUCTION WORKS-1

• Implementation plan considered

continuation of storage

operation during reconstruction

• External and internal works

• Organization of the project

• Time plans

• QA program with quality control

plan

• Program of radiological

protection

• Occupational safety plan


• External works:

• New water supply network to

the entrance of storage with

overhead hydrant for fire

safety

• Renewal of sewage system

with cesspit – close circuit

for all waters from storage

• Building of new engine room

for new ventilation drive and

filters units


• Internal work -presence of radioactive waste: work in 2 parallel sections

• Removal of transport equipment – lift,

• Remediation of minor damages on concrete,

• Repainting of the store walls and floor,

• Electric installation renovation, fire alarms installation,

• New forcible ventilation placement with system of pipelines in each of the sections and connected to the engine room.

EXPERIENCES DURING TRIAL OPERATION

• Work completed in may 2004 with

technical inspection.

• New safety functions installed:

• Ventilation system with filters

• Water collecting sump

• Physicall protection

• Fire protection

• Modification during trial experiences:

• Air drying system for humidity

decrease in the storage.

• Safety report:

• In accordance with Regulation E 2

• 13 chapters

• Inventory foreseen until 2018

• Update of licence in 2018


Operational conditions and limitations

• Operational limitations – doses:

• the annual effective dose to a member of critical group 0.1 mSv (administrative worker at the center),

• the annual effective dose for a worker in normal and abnormal operational conditions 10 mSv.

• The load of the ground floor should be administratively controlled – maximum from 1.3 t/m2 to 1.9 t/m2.

• One section has to remain empty in case of emergency (V suitable for app 4 m3 of radioactive waste).

• Ventilation before entering is needed – cRn < 650 Bq/m3.

• Total capacity in CISF is 145 m3 of radioactive waste (equivalent of 690 of 210 l drums).

• WAC for CISF: according to the requirements of JV 7, article 19.


Regulatory reviews and Inspections

• Safety Performance/Indicators

• Inspections

• Operating Experience Feedback

• Periodic Safety Review

• Management Meetings

• Integrated Safety Assessment

30

Safety Performance/Indicators

MONTHLY

QUARTERLY

YEARLY

PER FUEL CYCLE


Inspections

• No resident inspectors, the sites are very near

• Number of inspections varies dependin on the facility

• Yearly plan based on:

• Operating experience

• Observations in the previous years

• Unusual events

• Plan is prioritized based on safety significance

• Plan is adjusted during the year according to the needs

• Inspections assist licensing of modifications


Operating Experience Feedback

• Screening of incoming information from

different sources

• Selecting interesting cases

• Deeper analysis

• Discussion with the operators

• Implementation of lessons learned


Periodic Safety Review - PSR

• Every 10 years the facility must perform a thorough safety review

including:

• external influences to the facility

• design bases

• condition of SSC

• programmes

• procedures

• emergency preparedness

• organizational issues

• etc.

• Action plan for improvements must follow.

• PSR is a condition for continued operation and renewal of licence.


Management meetings

• Meeting of managers of the facility and

the SNSA.

• Open discussion about problems,

challenges and plans

• Good opportunity for better

understanding


SNSA Integrated Assessment System

RW repository

Inspections

Rumors

Licensing of

Changes

SNSA Management Meeting

(prescribed periods)

Feeling about the

Climate in the nuclear

facility

Third Party

News

BAD

Reporting Management

meetings

Safety Indicators

Outages

OEF Analyses


SNSA Communication Strategy

• Regular inspections and periodical reports

• First communicate it on technical level trying to “sell the idea”

• If not accepted: increase informal pressure – meeting with the management

• Only after that follows our order (decision).

• But still: administrative process is very demanding and could take a lot of time!


This project/activity is conducted by the IAEA, with funding by the European Union.

The views expressed in this publication do not necessarily

reflect the views of the European Commission.

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• WAC development


Regulatoty requirements -1

• WAC required by Nuclear Law based on JV 7: Regulation on RAW and SF management (2006), article 19 for all nuclear facilities: storages and disposals.

• Waste acceptance criteria for acceptance into storage or disposal are quantitative and qualitative requirements connected to characteristics of RAW (or SF), which must be fulfilled due to safety of RAW.

• The limitations must be provided for parameters:

• Radionuclide composition and specific activity

• Surface dose rate and rate at reference points

• Specific surface contamination

• Load resistance

• Leachability

• Corrosivity

• Chemical stability

• Heat generation

• Radiation stability


Regulatory requirements - 2

• Parameters - continuation:

• Ignitability

• Gas generation

• Poisoning constituents

• Organic materials with potential to biodegradation

• Free liquids

• Presence of chelating and complexing agents

• Explosivity

• Flammability

• Corrosion resistance

• Criticality

• Labeling

• Containers and packing

• Additionally some other limitations could arise form safety report or other documentation.

• Limitations must be defined for package, disposal unit and repository.

Process of determination of WAC for LILW

repository

Environmental/Spatial

planning law

Nuclear law Construction law Licence

Environmental report

(ER) as part of SIA

Special safety analyses Technical documents for

SSA

Opinion on ER

Spatial plan for

repository

Preliminary WAC Conceptual design Spatial plan ordinance

of national importance

for repository

Environmental impact

report

Safety report (SR) and

WAC for repository

Project for construction Construction licence,

environmental

consensus

SR, WAC As – built design Trial licence, licence for

facility use

Report on trial operation

SR, WAC Operation licence

Revision max on every

10 years


Broader assumptions and starting points

• Preliminary WAC for LILW repository according to JV7

regulations:

• Repository design (silo type of repository) in early

development stage – Preliminary design for LILW repository at

Vrbina location

• Assessment of total RW expected by 2037 (operational waste

from NPP, decommissioning waste (NPP, TRIGA and others),

waste from CISF) is not well defined in terms of V, radinuclide

content, activities and other characteristics

• Some wastes in storage (NPP) still need more characterisation

• Preliminary long-term safety assessment has been prepared,

but no calculations on radiological limitations of WAC for silo

type performed

• WAC for LILW repository are anticipated! and not calculated or

examined with measurements and PA


Design option: Vrbina,

Krško potential site

• Option B – near surface disposal in

silos (embankment)

• Site characteristics:

• Meteorology & climate

• Average precipitation: 1120 mm/y

• Flooding frequency 0.01%

• Hydrology: determined by Sava (290 m3/s) and Krka (54 m3/s) rivers

• Geology: simple structure on the site

• Gravel: 6-15m, very permeable – 2-4 m unsaturated

• Sandy silt: > 150m, low permeability; plastic


Silo type of repository proposed

Cross section of

silo disposal Layout of silo disposal


Preliminary WAC

• Developed:

• To define limitations for all relevant parameters in 19 article of

JV7 for variant B (silos) with possibility to adjust to another

variant or new location on the level of conceptual design for all

LILW

• To use available limitations from regulatory framework, NRC,

IAEA,…

• To use available practice from foreign repositories (El-Cabril,

Dukovany, Mochovce, Konrad, Forsmark, Olkiluoto,…)

• To consider 2 different WAC :

• for accepting waste into T&C facility at repository location,

• for disposal.

• To optimize acceptance in repository facility– to maximize the

possibility for operational RAW from NPP Krško

• To define parameters and limitations where additional analysis

must be performed

• To define mechanisms and mode of control of WAC parameters


Results -1

Properties WAC Parameters

(some examp.)

Limitations/remarks

Radiological RN content and

specific activity

List of critical RN

Total α conc.

Average α conc.

Conc. of indivi. β/γ

NEK, ARAO, PHARE

< 4000 Bq/g (pack.)

< 400 Bq/g (container)

LT SA (unit)

Characterisation and LT

SA

Surface dose

rate/0 and 1m

Surface dose rate

1m dose rate

Transport (con.cont.)

1m dose rate

<250 mSv/h

<25 m Sv/h

<2 mSv/h

<0.1 mSv/h

Surface

contamination

Spec. α contamination

Spec. β/γ contamination

<40 Bq/100 cm2

<400 Bq/100 cm2

Radiation

degradation

Organic material

Inorganic material

Modeling;If ECD>106

Gy-lab test

Modeling;If ECD>107

Gy-lab test


Results -2


(some examp.)

Limitations/remarks

Chemical Leachibility LIX

Diffusion coefficient

Leaching rate

>6, lab test

LT SA

LT SA

Free liquid content Same < 1 % of package

volume

Corrosivity pH

Corrosive mat. content

>5 and <9

List, < 1% of package

Corrosion

resistance

Wall thickness 300-years resistance to

expected corrosion

processes

Explosivity Elimination criteria

Gas generation

and complexing

agents

content List, < 1 % of total

mass, lab test


Results -3


(some examp.)

Limitati

ons/remarks

Mechanical Strenght RC structure

Concrete disposal container

RW package

LT SA

LT SA

Compressive and

tensile strenght

Thermal Ignitiability Elimination criteria

Flammability Fire resistance

Thermal cycle resistance

Testing

Lab test

Biological Organic

content

Same List, minimisation,

lab test

ID and

packaging

Package ID

method

Symbol

label

Method to identify

each package

Container types

and pack.

Methods

Metal cont.Pack. Method

Concrete cont. Pack method.

Treatment and final pack.

Design parameters


Results -4


(some examp.)

Limitations/remarks

Physical Permeability and

porosity

Permeability

Porosity

Lab test

Lab test

Homogeneity Same Identification

Density Same Design parameter/

homogeinity and

strenght

Void fraction Same < 0.5 % of package

volume, LT SA


Future work

• Prepare RN inventory: all waste for disposal – characterisation

and activation calculations. Introduce scaling factors.

• Prepare a list of long-term relevant critical RN.

• Perform LT PA/SA anlyses to determine the concentration limits

for RN for disposal package, container and unit.

• Modell repository conditions with regard to radiation stability.

• Set up the limit values for leachability, strenght, void fraction,

toxic constituents from LT SA.

• Select a type of lab tests for different radioactive waste package

properties (radiation degradation, leachability, free liquid content,

corrosivity, chelating content, toxic, constituents, gas generation,

flammability, …)

• Prepare list and evaluate different limiting values content

(corrosive material, chelating agents, toxic content, gas generation

material, organic material,).

• Define conditions for tests of drop and fire resistance for disposal

containers.


Conclusions

• Proposed WAC for LILW repository are uncertain to a large extent,

particularly with regard to the quantitative aspects that sets up

limits for particular parameters.

• Therefore, a proposal is prepared for future actions that should be

taken in order to reduce present ambiguities.

• Optimization of more realistic quantitative limits values shall be

done in later stage.

• Periodical revisions of WAC will comply with the progress of the

repository design development:

• defining of design for repository,

• verification of safety parameters by long-term PA/SA and

• calculations of radiological limitations with available

approaches.

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