1CN-242/124
Regulatory Approach for the Assessment of the Licence Application for Radioactive Waste Management Facilities in Australia
S. Sarkar
Regulatory Services Branch, Australian Radiation Protection and Nuclear Safety Agency (ARPANSA), PO Box 658, Miranda, NSW 1490, Australia
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Abstract. Thispaper describes the regulatory approach of Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) for assessing the operating licence application for radioactive waste management facilities. These facilities relate to predisposal management of radioactive waste. ARPANSA is the regulatory authority for commonwealth entities operating nuclear installations including radioactive waste management facilities. In assessing the application for nuclear installations the ARPANSA assessors prepare a Regulatory Assessment Report (RAR), which is a recommendation to the Chief Executive Officer (CEO) of ARPANSA whether to issue a licence to site, construct, operate and decommission facilities. The key elements of ARPANSA’s assessment include plans and arrangements for managing safety, safety case, use of defence-in-depth and conservative proven design and engineering practice, operational limits and conditions, and use of international best practice. Compliance monitoring of licenced facilities are undertaken through regular reporting, site visits and a risk-based planned inspection program.
Key words: radioactive waste management, regulatory assessment, predisposal management
- Introduction
In Australia the main legislation and regulatory framework governing the safety of nuclear installation, radiation facilities and radioactive material is the Australian Radiation Protection and Nuclear Safety Agency Act 1998 (the Act)and the Australian Radiation Protection and Nuclear Safety Regulations 1999 (the Regulations). The objective of the Act is to protect the health and safety of people and the environment from the harmful effects of radiation. The Act gives the CEO power to attach conditions to the licence for operation of the facility.
Nuclear installations that operate under ARPANSA facility licence include research reactor, radioisotopes production facilities, radioactive waste management and spent fuel management facilities. All of Australia’s existing nuclear installations are under the effective control of the Australian Nuclear Science and Technology Organisation (ANSTO).Though some other Commonwealth entities operate radioactive waste management facilities nuclear operational wastes are managed by ANSTO. The licensed waste management facilities operated by ANSTO include:
- Low level solid waste facilities for handling, processing and storage
- Intermediate level solid waste facilities including storage of vitrified waste generated from reprocessing of research reactor fuel, and various solid waste and solid waste containing LEU generated from production of molybdenum-99
- Low level liquid waste including storage, treatment and conditioning
- Storage of intermediate level liquid waste
- Storage of nuclear materials and safeguards materials
In 2014, ARPANSA issued the licence to site and construct an intermediate level liquid waste conditioning facility to process the intermediate level liquid waste generating from the production of molybdenum-99. Synroc (synthetic rock) technology, developed by ANSTO,will be used to condition such intermediate level liquid waste.
- Discussion
The ARPANSA regulatory approach is non-prescriptive but provides guidance and therefore, the licence holder has flexibility in developing plans and arrangements to give appropriate safety. To help judge the adequacy of the plans and arrangements, and safety cases ARPANSA has published Regulatory Guidelines [1], Regulatory Assessment Principles [2] and Regulatory Assessment Criteria [3]. These have been developed drawing on past experience, best practice and international standards such as International Atomic Energy Agency (IAEA).
An updated safety case is required for each of the principal stages in the life of a facility. The safety case includes the design information for the facility, including the operational limits and conditions (OLCs) within which the facility must operate, and a safety analysis that is documented in the safety analysis report (SAR).The extent and rigour of the SAR should be commensurate with the hazard categorisation of the facility. The margins between the operational limits and conditions and the relevant safety limits are included in the SAR.As part of the safety analysis report the licence holder must categorise the hazard associated with the facility and also categorise systems, structures and components by their safety significance.
The safety analysis establishes the hazard of the facility according to the following categories:
- Hazard Category F1: where there is no potential for significant[1]consequences outside the facility.
- Hazard Category F2: where there is potential for significant1 consequences on the site outside the facility, but not outside the site.
- Hazard Category F3: where there is potential for significant1 consequences outside the site
The responsibility for demonstrating each relevant assessment principle rests wholly with the licence holder. The operating organisation’s safety analysis can assist in demonstrating safety to ARPANSA. An alternative to an ARPANSA principle may be acceptable to the CEO of ARPANSA if the operating organisation clearly demonstrates that the alternative principle provides a degree of safety based on the application of contemporaneous international best practice in radiation protection and nuclear safety.
Regulatory assessment (safety evaluation) of the information described in the application is the key aspect for granting authorisation to operate a nuclear installation. Of particular importance in safety evaluation for a facility licence are the plans and arrangements for managing safety. These plans require the demonstration of appropriate arrangements for:
- effective control;
- safety management;
- radiation protection;
- radioactive waste management;
- security;
- emergency; and
- environment protection
The plans and arrangements for managing safety are then assessed against regulatory guidelines developed by ARPANSA [1]. In addition safety case is assessed against ARPANSA’ assessment principles [2] and criteria [3] and the requirements of the international standards such as those of the IAEA.
A licence may be subject to conditions as set out in the ARPANS Act and Regulations; or imposed by the CEO. Such licence conditions are not surrogates for safety; they outline certain additional requirements placed on the licence holder that will assure the CEO of ARPANSA that the licence holder is undertaking the licensed activity safely.
- Results
After assessing all the relevant information ARPANSA assessors prepared a regulatory assessment report (RAR), which is a recommendation to the CEO of ARPANSA whether to issue a licence to operate[2] the waste management facilities. This report was based on the results of the detailed assessment of the application and the resolution of issues resulted from any public submission on the application. The RAR is a complete assessment of the application for an authorisation to operate the waste management facilities. This report demonstrates that the conduct for which the licence is sought can be effectively controlled to provide adequate protection to the health and safety of the people and the environment. The operation of the ANSTO waste management facilities are currently subjected to six licence conditions as they relate to compliance reporting, periodic performance assessment and discharge of radioactive waste, and compliance with OLCs.
- Compliance Monitoring
Apart from regular reporting (quarterly and annually) by the licence holder and regular site visits, a long-term schedule of inspection is used for regulatory compliance monitoring. The complexity and riskinherent in each facility determines the scope and duration of each inspection. The scope of the inspection is determined based on risk using a graded approach.There are eight inspection areas covered during the baseline inspection period. For example, a single inspection may last two weeks and involve just one of the eight areas; it may, on the other hand, involve four areas and last only two days.
The following inspection areas, which are comprised of more specific modules, collectively known as the Performance Objectives and Criteria, constitute the baseline schedule for each licence. These areas are broad in scope and intended to cover all aspects of licence holder performance.
(i) Performance Reporting Verification: address the reporting culture, both internally and externally, including discrepant or unreported performance data, performance indicator verification, and compliance with operating limits and conditions.
(ii)Configuration Management: include evaluation of facility modifications, equipment alignment, operability determinations, temporary facility modifications, and safety system design and capability.
(iii) Inspection, Testing, and Maintenance: include post-maintenance testing, in-service testing and inspection, surveillance testing, and maintenance and work control.
(iv) Training: address personnel training, the use of a systematic approach to training, accredited operator training, etc.
(v) Event Protection: include adverse weather, fire protection, flooding, bush fires,land management, etc.
(vi) Security: include aspects of security arrangements and requirements. Modules also include infrequently conducted tests or evolutions, outage performance, etc.
(vii) Radiation Protection: include access control, dosimetry, ALARA planning, radiation monitoring instrumentation, effluent system monitoring, radioactive material processing and transportation, etc.
(viii) Emergency Preparedness and Response: include exercises and drills, emergency response organisation testing, notification testing, etc.
There are also three cross-cutting aspects that may be addressed in each inspection, namely, Human Performance, safety Culture, Performance Improvement.
- Conclusion
The matters and process considered in the regulatory assessment provide an effective and efficient regulatory approach for safe and secure operation of nuclear and radiation facilities including radioactive waste management facilities. Australian government is planning to construct a National Radioactive Management Facility (NRWMF) to provide a centralised location for the disposal of low level waste and storage of intermediate level solid waste facilities. ARPANSA will apply similar regulatory approach to the NRWMF.
- References
[1]Australian Radiation Protection and Nuclear Safety Agency, ARPANSA, Regulatory Guide: Plans and Arrangements for Managing Safety, (2014)
[2]Australian Radiation Protection and Nuclear Safety Agency, ARPANSA, Regulatory Assessment Principles for Controlled Facilities, RB-STD-42-00, (2001)
[3]Australian Radiation Protection and Nuclear Safety Agency, ARPANSA,Regulatory Assessment Criteria for the Design of New Controlled Facilities and Modifications to Existing Facilities, RB-STD-43-00, (2001)
[1] Some judgement is required on significance and guidance is given in the Regulatory Assessment Principles and also need to be addressed in the SAR
[2]the RAR is also prepared for the CEO whether to issue a licence for siting, construction and decommissioning of facility