There are 3 source licence application forms - the choice of form depends on the hazard of the source(s): Group 1 sources are considered low hazard, Group 2 sources are considered medium hazard and Group 3 sources are considered high hazard. Section 4 of the Australian Radiation Protection and Nuclear Safety Regulations 2018 (the Regulations) describes the types of sources in each group and this will assist you to select the correct application form.
Completing the application form
Section A: Applicant Information
Department or Commonwealth entity
This is the name of the Department or entity on behalf of which the application is being made. It may include further information for ease of identification, e.g. Division, Branch, Section.
Portfolio
Name of the Commonwealth ministerial portfolio in which the Department or entity resides.
Applicant/Responsible Person
The application must be made by the chief executive of the Department or entity or by a person authorised by the chief executive.
The applicant must provide their full name, position and business address. If it is made by an authorised person, the application must include a copy of the authorisation.
Note 1: Responsible Person in relation to any radiation source, prescribed radiation facility or premises on which radiation sources are stored or used means the legal person: (a) having overall management responsibility including responsibility for the security and maintenance of the radiation source, facility or premises (b) having overall control over who may use the radiation source, facility or premises (c) in whose name the radiation source, facility or premises would be registered if this is required. RPS C-1 Code for Radiation Protection in Planned Exposure Situations
Nominee
If the applicant is physically removed from the source dealing, such that they cannot demonstrate effective control, the name and contact details of a person more directly in control of the source dealing must be provided. This nominee must be in effective control of the sources. Generally, the nominee will be the manager of a division or agency’s operation at the site of the proposed activity or, in the case of mobile or portable devices, where the devices are usually stored. Other nominees may also be acceptable where the hazards of the activity are low and only minimal control is required. If a nominee is appointed, an organisational chart should be provided showing the relationship of the nominee to the applicant and end users.
Radiation Safety Officer (RSO)
This is an individual appointed by the applicant to supervise radiation safety in relation to the sources for which the licence is sought. This person must be technically competent in radiation protection matters relevant to all sources, including non-ionising radiation sources if these are part of the application. Evidence of competency should be included. If there is more than one radiation safety officer, the details of other radiation safety officers should also be provided.
The declaration must be signed by the applicant or authorised person.
Section B: Description of the source and proposed dealing
Indicate the kind of controlled apparatus and/or controlled material in the table provided. If there is any doubt about the hazard category or description of a source the applicant should seek advice from Regulatory Services on (02) 9541 8333.
Describe the source, the proposed dealing, and provide the full site address where the sources will be used or stored.
Section C: Source details
Section 47 of the Regulations sets out the information that must be provided about the sources to be dealt with under the licence. This must include the information shown in the table below.
A dealing with a sealed source
(a) the nuclide, activity, chemical form, encapsulation material and physical form of the sealed source
(b) the purpose and identification details of the sealed source
(c) the place where the sealed source is to be located
(d) a copy of any sealed source certificate for the sealed source
A dealing with an unsealed source
(a) the nuclide, chemical form and physical form of the unsealed source
(b) the purpose and identification details of the unsealed source
(c) the maximum activity of each nuclide to be held on particular premises at any one time
(d) the place where the unsealed source is to be located
A dealing with a controlled apparatus that produces ionizing radiation
(a) the purpose and identification details of the controlled apparatus
(b) the maximum kilovoltage
(c) the place where the controlled apparatus is used
A dealing with a controlled apparatus that produces non‑ionizing radiation
(a) the purpose and identification details of the controlled apparatus
(b) the likely exposure levels including the nature of the radiation
(c) all output parameters relevant to the likely exposure conditions
(d) the place where the controlled apparatus is used
The details of all sources should be recorded in a source inventory workbook (SIW) which is an Excel spreadsheet available here. This is the form approved by the CEO for maintaining source records.
An explanation of terms and required information appears in the first worksheet. The completed SIW must be submitted with the application.
Section D: Plans & arrangements for managing safety
The applicant must have plans and arrangements for managing sources to ensure the health and safety of people and protection of the environment. These should be a comprehensive program of policies and procedures that demonstrate how radiation safety will be ensured. The content of these plans and arrangements will vary depending on the hazard and complexity of the sources to be dealt with.
There is no pre-determined format for supplying this information. The applicant may either describe the plans and arrangements on the application form or may reference suitable organisational documents. If the latter option is taken, the applicant must clearly indicate on the application form where the relevant information can be found within accompanying documents.
Applicants should identify the codes and standards relevant to the proposed dealing and describe how these will be implemented or taken into account in managing the safety of sources. This information may be incorporated into Section D of the licence application.
Codes and standards applicable to each kind of source can be found here. These codes and standards will become conditions of licence should the application be approved.
ARPANSA publishes information about international best practice (IBP) with links to international codes and standards that may be relevant to the proposed dealing. The applicant is advised to consider these where relevant.
Depending on the type of source, the applicant may be required to address some or all of the following:
Effective Control Arrangements
Provide information to demonstrate how the applicant or nominee will maintain control over the particular dealings for which a licence is sought. The arrangements should cover such things as organisational arrangements, management systems and resources.
Safety Management Plan
Describe the administrative arrangements for managing safety. These arrangements may be minimal, where only low hazards are involved, but will be more extensive for dealings of higher hazard or complexity. The safety management plan should cover things such as safety culture, safety of premises and equipment, competency and training, incidents, auditing and record keeping.
The radiation protection plan should cover issues such as principles of radiation protection, planning and design of the workplace, classification of work area, local procedures, radiation monitoring of individuals and the workplace and protection of the environment.
Where sources are to be used for medical purposes, the plans and arrangements should address the requirements of RPS C-5 Code for radiation protection in medical exposure and associated safety guides for diagnostic and interventional radiology, radiotherapy, and nuclear medicine; in particular, addressing optimisation of exposure and radiation protection of the patient.
In addition, the applicant is responsible for ensuring that arrangements are implemented for the appointment of a suitably qualified radiation safety officer and/or radiation safety committee as appropriate. Information should be provided about the qualifications and experience of such persons and the arrangements in place for their continued competency.
Radioactive Waste Management Plan
A full description and anticipated amounts of any radioactive wastes, including discharges arising from the proposed dealing and the arrangements for the safe handling, treatment, storage and disposal of any such waste should be set out in a radioactive waste management plan.
Provide a plan for the ultimate transfer or disposal of sources. Copies of documented undertakings by other organisations to accept sources when no longer required should be provided where possible. Applicants should note that after a licence is issued, section 65 of the Regulations applies to the disposal and transfer of sources.
Describe the arrangements for the security of sources to prevent theft, damage or unauthorised access. These arrangements should ensure that control of sources is not relinquished without appropriate approvals required by the Regulations and conditions of licence. The plan should provide for periodic inventory checks to confirm that all sources are secure and in their assigned location.
Note 4: A security enhanced source is a radioactive source or aggregation of sources assigned Security Category 1, 2 or 3 when using the methodology set out in Schedule B of RPS 11.
Emergency Plan
Emergency arrangements must be developed for all foreseeable emergencies such as dispersion of materials, overexposure of operators, or theft or loss of controlled material. The arrangements should include: the responsibilities of all parties in the event of an emergency; contact arrangements; emergency procedures; emergency equipment; and reporting arrangements. Where necessary, arrangements for involving external agencies such as police and other emergency services should be included.
The plan should include arrangements for testing the emergency arrangements through regular reviews and exercises and rectifying any deficiencies found in the emergency plans.
Section E: Matters to be taken into account by the CEO
Subsection 33(3) of the Australian Radiation Protection and Nuclear Safety Act 1998 (the Act) requires the CEO to take into account international best practice in relation to radiation protection and nuclear safety when making a decision whether to issue a source licence. The CEO must also take into account the matters prescribed in section 53 of the Regulations. Provide information on these matters in Section E for the CEO to consider.
International best practice in radiation protection and nuclear safety
Describe how international best practice (IBP) has been considered in relation to the facility relevant to the type of authorisation sought.
Each element of the proposed activity should be researched to determine what can be regarded as IBP. Undertaking research and benchmarking exercises are a useful way to establish IBP.
Implementation of relevant national and international codes and standards is considered a demonstration of best practice.
Provide information to demonstrate that sources can be dealt with without undue risk to the health and safety of people and the environment. This should include evidence that the radiation risks to people and the environment arising from the proposed dealing have been fully assessed, including the probability and magnitude of potential exposures arising from incident scenarios and abnormal occurrences.
Net benefit
Provide information to demonstrate that dealing with sources produces sufficient benefit to individuals or to society to offset the radiation harm that it might cause, taking into account societal, economic and other relevant factors; that is, the applicant must justify the dealing and demonstrate a net benefit from it.
Optimisation of protection
Provide information to demonstrate that protection has been optimised. The level of protection should be the best under prevailing circumstances and should provide for an adequate margin of benefit over harm. Information should show that the likelihood of incurring exposures, the number of people exposed, and the magnitude of exposures are as low as reasonably achievable, having regard to economic and societal factors. Information such as actual dose information, including dosimeter readings and surveys or sample dose calculations or both could be provided for this purpose.
Technical, human and organisational factors
Provide information to demonstrate that interactions between technical, human and organisational factors have been considered in the management of safety.
Human factors involve understanding human capability and limitations in operational and maintenance roles relating to sources. There are a variety of human factors assessments that can be used to both understand and demonstrate the management of safety critical risks.
Organisational factors are aspects of the organisation that facilitate performance (in safety), e.g. culture, safety management systems, leadership, resilience, defence-in-depth. Organisational factors can be addressed through a variety of self-reflective practices and systemic design.
Technical factors include the design, operation and maintenance of equipment, machinery and tools. It is important the organisation thinks about the ways in which humans will respond, adapt, and learn from organisational and technical factors.
Provide information to demonstrate that the applicant has the capacity to comply with the Regulations and licence conditions that would be imposed under section 35 of the Act.
Evidence of compliance with similar legislation such as that administered by Comcare or the Australian Safeguards and Non-Proliferation Office (ASNO) may be useful for this purpose. A current ARPANSA licence holder may refer to their compliance history.
Provide information to demonstrate that there are sufficient financial and human resources to safely deal with sources.
Authorised signatory
The application must be signed by an office holder of the applicant or a formally authorised person. An office holder is the Secretary, Chief Executive Officer or an equivalent person of the Department or entity that is named as the applicant. Where a person authorised by an office holder of the applicant signs the application, a copy of the instrument of authorisation must be provided.
Checklist
A checklist is provided to confirm the application is complete.
Application fee
Refer to section 49 of the Regulations to determine the appropriate fee. The fee must be received before the application can be assessed. Accepted payment methods are EFT, credit card or BPAY – please see Payment methods | ARPANSA.
When your application is submitted it will be examined to see if all the necessary information is included, if it is properly signed, and if the correct application fee has been paid. If so, you will receive an acknowledgment email. If any of the basic information is missing, you will be contacted for further information or in some cases the application and fee may be returned.
Your application will then be forwarded to a regulatory officer. The regulatory officer will discuss and agree a time with you to complete the assessment.
The regulatory officer will review all the information and consider the claims, evidence and arguments presented. Where matters require clarification, the regulatory officer will contact you or your nominee. The regulatory officer may also consider that an inspection or site visit is necessary and will contact you to arrange this. The officer will then prepare a regulatory assessment report to document the review.
The assessment report will make a recommendation to the CEO about whether to issue a licence and may recommend licence conditions to be imposed under section 35 of the Act. The report undergoes a rigorous review and approval process prior to being sent to the decision maker with all relevant documentation. You will be advised in writing of the decision.
Under section 37 of the Act, a licence may be issued indefinitely or for a period specified in the licence. When issued, a licence remains in force until it is cancelled or surrendered, or the specified period has elapsed.
Appealing a licence decision
Section 40 of the Act describes the rights of review available to eligible persons in respect of licence decisions made by the CEO. The following decisions are reviewable:
a) to refuse to grant a licence b) to impose conditions on a licence c) to suspend a licence d) to cancel a licence e) to amend a licence f) not to approve the surrender of a licence g) to issue a licence for a particular period, rather than for a longer period or indefinitely h) not to extend the period for which a licence was issued
An eligible person in relation to a decision to refuse to grant a licence means the person who applied for the licence, and in relation to any other licence decision, it is the licence holder.
Review by the Minister
Should an applicant wish to have a licence decision reviewed, the applicant may request the Minister for Health to review the decision. The request must be in writing and be given to the Minister within 28 days of the making of the licence decision. Once a request for review has been lodged, the Minister must reconsider the licence decision and confirm, vary or set aside the decision.
The Minister is taken to have confirmed the licence decision if the Minister does not give written notice of the Minister’s decision within 60 days of the request.
Review by the Administrative Review Tribunal (ART)
An application may be made to the ART for review of a decision of the Minister.
Name of the Department or Commonwealth Body on behalf of which the application is being made. It may include further information for ease of identification e.g. Division, Branch, Section etc.
Portfolio
Name of the Commonwealth ministerial portfolio in which the Department or entity resides.
Applicant/Responsible Person
The application must be made by the chief executive of the Department or entity or by a person authorised by the chief executive.
The applicant must provide their full name, position and business address. If it is made by an authorised person, the application must include a copy of the authorisation.
Note 1: Responsible person in relation to any radiation source, prescribed radiation facility or premises on which radiation sources are stored or used means the legal person: (a) having overall management responsibility including responsibility for the security and maintenance of the radiation source, facility or premises (b) having overall control over who may use the radiation source, facility or premises (c) in whose name the radiation source, facility or premises would be registered if this is required.RPS C-1 Code for Radiation Protection in Planned Exposure Situations
Nominee
If the applicant is sufficiently removed from the facility that they cannot demonstrate effective control, the name and contact details of a person more directly in control of the PRF must be provided. This nominee must be in effective control of the PRF. Generally the nominee will be the manager of a division or agency’s operation at the site of the proposed activity. If a nominee is appointed, an organisational chart should be provided, showing the relationship of the nominee to the applicant and the operators.
Radiation Safety Officer
This is an individual appointed by the applicant to supervise radiation safety in relation to the controlled facility, controlled apparatus and/or controlled material for which the licence is sought. This person must be technically competent in radiation protection matters relevant to the facility and any associated sources. Evidence of competency should be included in the application. If there is more than one radiation safety officer, the details of other radiation safety officers should also be provided.
The declaration must be signed by the applicant or authorised person.
Section B: Kind of prescribed radiation facility
The applicant must indicate the kind of PRF for which a licence is sought.
Section C: Type of authorisation
The applicant must indicate the type of authorisation sought relevant to the life cycle of the facility.
Note 3: Under certain circumstances, the CEO of ARPANSA may exempt an applicant from the need to be authorised for certain conduct relating to a facility. For example, the CEO may exempt an applicant from the need for a siting licence where they intend to construct a similar facility on a previously authorised site. For more information on such exemptions, applicants should contact ARPANSA.
Section D: Facility Details
Provide a detailed description of the facility and its site including the site address. Include this information in the space provided or insert references to where this information can be found in supporting documents. The full title, version/edition, and approval date should be provided for all referenced documents.
Section E: Safety Analysis Report
A safety analysis report (SAR) must be provided for each type of authorisation sought. The SAR must be as complete as possible for each stage of licensing. If applying to prepare a site for and construct a nuclear installation in the same application a SAR that is as complete as possible must be provided for each stage.
The applicant must have plans and arrangements for managing the facility to ensure the health and safety of people and protection of the environment.
These should be a comprehensive program of policies and procedures that demonstrate how safety and security will be ensured. The content of these plans and arrangements will vary depending on the hazard and complexity of the facility.
There is no predetermined format for supplying this information. The applicant may either describe the plans and arrangements in the space provided or may reference suitable organisational documents. If the latter option is taken, the applicant must clearly indicate on the application form where the relevant information can be found within accompanying documents and provide the full title, version/edition, and/or approval date.
If there are sources associated with the proposed facility, the applicant should identify the relevant codes and/or standards and describe how compliance with these documents will be achieved. This information may be included in Section F of the application. Codes and standards applicable to each kind of source can be found here. Codes and standards applicable to PRFs can be found here.
ARPANSA also publishes international best practice (IBP) information with links to various international codes and standards that may be relevant to the proposed facility. Applicants should identify relevant IBP and describe how this will be implemented or taken into account.
Effective Control Arrangements
Provide information to demonstrate how the applicant or nominee will establish and maintain effective control over the facility. This should cover issues such as organisational arrangements, management systems and resources.
Safety Management Plan
Describe the administrative arrangements for managing the safety of the facility and any associated sources. This should cover issues such as safety culture, safety of premises and equipment, competency and training, incidents, auditing and record keeping.
The radiation protection plan should cover issues such as principles of radiation protection, planning and design of the workplace, classification of work area, local procedures, radiation monitoring of individuals and the workplace.
In addition, the applicant is responsible for ensuring that arrangements are implemented for the appointment of a suitably qualified radiation safety officer and/or radiation safety committee as appropriate. Provide information about the qualifications and experience of such persons and the arrangements in place for their continued competency.
Radioactive Waste Management Plan
A full description and anticipated amounts of any radioactive wastes, including discharges arising from the proposed conduct and the arrangements for the safe handling, treatment, storage and disposal of any such waste should be set out in a radioactive waste management plan.
Describe the arrangements for the security of the facility and any associated sources to prevent theft, damage or unauthorised access. These arrangements should demonstrate how the security of the facility will be maintained and how periodic inventory checks will be undertaken to confirm that all sources are in their assigned locations and are secure.
Emergency arrangements should be developed for all foreseeable emergencies such as dispersion of materials, over-exposure of operators, or theft or loss of controlled material. The level of detail should be commensurate with the hazard of the facility. The arrangements should include the responsibilities of all parties in the event of an emergency, contact arrangements, emergency procedures, emergency equipment and reporting arrangements. Where necessary, arrangements for involving external agencies such as police and other emergency services should be included.
The plan should include arrangements for testing the emergency arrangements through regular reviews and exercises, and rectifying any deficiencies found in the emergency plans.
Arrangements should be developed for the protection of wildlife populations and ecosystems in parallel with radiation protection of people, consistent with international best practice. The arrangements should include identification of all potential exposure scenarios and pathways to the environment and affected biota with environmental radiological assessments of wildlife in their natural habitats based on the concept of reference organisms. Refer to RPS G-1 Guide for Radiation Protection of the Environment.
Decommissioning Plan
Arrangements should be developed that demonstrate adequate planning for decommissioning to protect workers, the public and the environment. While most decommissioning activities take place in the final phase of a facility’s lifecycle, decommissioning should be considered as early as possible. An initial decommissioning plan should be developed at the design stage and periodically updated throughout subsequent life stages. The objective is to develop a final plan to be submitted when applying for authorisation to decommission the facility.
Provide the additional information as shown in the table in section 46 of the Regulations specific to the type of authorisation sought. Enter the information in the space provided or state clearly where this information can be found in the accompanying documentation. The full title, version/edition, and approval date should be provided for all referenced documents.
Prepare a site for a PRF
Provide the following information to support a facility application to prepare a site for a PRF:
A detailed site evaluation establishing the suitability of the site
A description of the characteristics of the site, including the extent to which the site may be affected by natural and human events
Any environmental impact statement (however described) requested or required by a Commonwealth, state, territory or local government agency in relation to the site or facility, and the outcome of the environmental assessment
Construct a PRF
Provide the following information in support of a facility licence application to construct a PRF:
The design of the facility, including ways in which the design deals with the physical and environmental characteristics of the site
Any fundamental difficulties that will need to be resolved before any facility licence relating to the facility is issued
The construction plan and schedule
The arrangements for testing and commissioning safety related items
Possess or control a PRF
Provide the following information in support of a facility licence application to possess or control a PRF:
The arrangements for maintaining criticality safety during loading, moving or storing nuclear fuel and other fissile materials at the controlled facility
The arrangements for safe storage of controlled material and maintaining the facility
Operate a PRF
Provide the following information in support of the application to operate a PRF:
A description of the structures, components, systems and equipment of the facility as they have been constructed
The operational limits and conditions of the facility
The arrangements for commissioning the facility
The arrangements for operating the facility
Results of a field exercise to respond to a scenario that involves an emergency and has been agreed with the CEO
Decommission a prescribed radiation facility
Provide the following information in support of the application to decommission a PRF:
Schedule for decommissioning the facility
Dispose of or abandon a prescribed radiation facility
Provide the following information in support of an application to decommission a PRF:
Results of decommissioning activities at the facility
Details of any environmental monitoring program proposed for the site of the facility
Section H: Associated sources
Sources that are part of, used in connection with, produced by, incorporated in, stored in, or disposed of in, a facility do not require a separate source licence, but must be authorised by the facility licence.
Not all facilities have associated sources but where they do the applicant must indicate the kind of sources in Section H of the application. Common types of sources used in facilities are calibration sources. For sealed sources, a copy of any source certificate should be provided.
Section I: Source details
The details of any sources associated with the facility must be recorded in a source inventory workbook (SIW). This is the form approved by the CEO for maintaining source records. The SIW template is available here.
An explanation of terms and required information appears in the first worksheet of the SIW. If in doubt, contact ARPANSA for advice. The completed SIW is to be submitted with the application.
Section J: Matters to be taken into account by the CEO
Subsections 32(3) and 33(3) of the Act require the CEO to take into account international best practice in relation to radiation protection and nuclear safety when making a decision whether to issue a licence. The CEO is also required to take into account the matters prescribed in section 53 of the Regulations. Provide information on these matters in Section J of the application form.
International best practice in radiation protection and nuclear safety
Describe how international best practice (IBP) has been considered in relation to the facility relevant to the type of authorisation sought.
Each element of the proposed activity should be researched to determine what can be regarded as IBP. Undertaking research and benchmarking exercises are useful ways to establish IBP. Implementation of relevant national and international codes and standards is considered a demonstration of best practice.
Provide information to demonstrate that the proposed conduct can be undertaken without undue risk to the health and safety of people and the environment. This should include evidence that the radiation risks to people and the environment arising from the proposed conduct have been fully assessed, including the probability and magnitude of potential exposures arising from incident scenarios and abnormal occurrences.
Net benefit
Provide information to demonstrate that the proposed conduct produces sufficient benefit to individuals or to society to offset the radiation harm that it might cause, taking into account social, economic and other relevant factors; that is, the applicant must justify the conduct and demonstrate a net benefit from it.
Optimisation of protection
Provide information to demonstrate that protection has been optimised. The level of protection should be the best under prevailing circumstances and should provide for an adequate margin of benefit over harm. Information should show that the likelihood of incurring exposures, the number of people exposed and the magnitude of exposures are as low as reasonably achievable, having regard to economic and societal factors. Information such as actual dose information, including dosimeter readings and surveys or sample dose calculations or both could be provided for this purpose.
Technical, human and organisational factors
Provide information to demonstrate that interactions between technical, human and organisational factors have been considered in the management of safety.
Human factors involve understanding human capability and limitations in operational and maintenance roles relating to the PRF. There are a variety of human factors assessments that can be used to both understand and demonstrate the management of safety critical risks.
Organisational factors are aspects of the organisation that facilitate performance (in safety), eg. culture, safety management systems, leadership, resilience, defence-in-depth. Organisational factors can be addressed through a variety of self-reflective practices and systemic design.
Technical factors include the design, operation and maintenance of equipment, machinery and tools. It is important the organisation thinks about the ways in which humans will respond, adapt, and learn from organisational and technical factors.
Provide information to demonstrate that there is capacity to comply with the Regulations and licence conditions that would be imposed under section 35 of the Act.
Evidence of compliance with similar legislation such as that administered by Comcare or the Australian Safeguards and Non-Proliferation Office (ASNO) may be useful for this purpose. A current ARPANSA licence holder may refer to their compliance history.
Provide information to demonstrate that there are sufficient financial and human resources to safely undertake the proposed conduct.
Authorised signatory
The application must be signed by an office holder of the applicant or a formally authorised person. An office holder is the Secretary, Chief Executive
Officer or an equivalent person of the Department or entity that is named as the applicant. Where a person authorised by an office holder of the applicant signs the application, a copy of the instrument of authorisation must be provided.
Checklist
A checklist is provided to confirm the application is complete.
Application fee
Refer to section 49 of the Regulations to determine the appropriate application fee. The fee must be received before the application can be assessed. Accepted payment methods are EFT, credit card or BPAY – please see payment methods.
When your application is submitted it will be examined to see if all the necessary information is included, if it is properly signed, and if the correct application fee has been paid. If so, you will receive an acknowledgment email. If any of the basic information is missing you will be contacted for further information or in some cases the application and fee may be returned.
As soon as practicable after receiving your application, and after confirming it is complete, the CEO is required by section 48 of the Regulations to publish a notice in a national daily newspaper and on ARPANSA’s website, stating the intention to make a decision on the application.
Your application is then forwarded to a regulatory officer. The regulatory officer will discuss and agree a time with you to complete the assessment.
The regulatory officer will review all the information and consider the claims, evidence and arguments presented. Where matters require clarification, the regulatory officer will contact you or your nominee. The regulatory officer may also consider that an inspection or site visit is necessary and will contact you to arrange. The officer will then prepare a regulatory assessment report to document the review.
The assessment report will make a recommendation to the CEO about whether to issue a licence and may recommend licence conditions to be imposed under section 35 of the Act. The report undergoes a rigorous review and approval process prior to being sent to the decision maker with all relevant documentation.
You will be advised in writing of the decision. The CEO may also publish a ‘statement of reasons’ for the decision on this website.
Detailed information about how ARPANSA undertakes assessments can be found in our Review & Assessment Manual on the 'how we regulate' page.
Under section 37 of the Act, a licence may be issued indefinitely or for a specified period. When issued a licence remains in force until it is cancelled or surrendered, or the specified period has elapsed.
Appealing a licence decision
Section 40 of the Act describes the rights of review available to eligible persons in respect of licence decisions made by the CEO. The following decisions are reviewable:
to refuse to grant a licence
to impose conditions on a licence
to suspend a licence
to cancel a licence
to amend a licence
not to approve the surrender of a licence
to issue a licence for a particular period, rather than for a longer period or indefinitely
not to extend the period for which a licence was issued
An eligible person in relation to a decision to refuse to grant a licence means the person who applied for the licence, and in relation to any other licence decision, it is the licence holder.
Review by the Minister
Should an applicant wish to have a licence decision reviewed, the applicant may request the Minister for Health to review the decision. The request must be in writing and be given to the Minister within 28 days of the making of the licence decision.
If a request for review is lodged, the Minister must reconsider the licence decision and confirm, vary or set aside the decision.
The Minister is taken to have confirmed the licence decision if the Minister does not give written notice within 60 days of the request.
Review by the Administrative Review Tribunal (ART)
An application may be made to the ART for review of a decision of the Minister.
Name of the Department or Commonwealth Body on behalf of which the application is being made. It may include further information for ease of identification e.g. Division, Branch, Section etc
Portfolio
Name of the Commonwealth ministerial portfolio in which the Department or entity resides.
Applicant/Responsible Person
The application must be made by the chief executive of the Department or entity or by a person authorised by the chief executive.
The applicant must provide their full name, position and business address. If it is made by an authorised person, the application must include a copy of the authorisation.
Note 1: Responsible person in relation to any radiation source, prescribed radiation facility or premises on which radiation sources are stored or used means the legal person: (a) having overall management responsibility including responsibility for the security and maintenance of the radiation source, facility or premises (b) having overall control over who may use the radiation source, facility or premises (c) in whose name the radiation source, facility or premises would be registered if this is required. RPS C-1 Code for Radiation Protection in Planned Exposure Situations
Nominee
If the applicant is physically removed from the facility such that they cannot demonstrate effective control, the name and contact details of a person more directly in control of the facility must be provided. This nominee must be in effective control of the nuclear installation. Generally the nominee will be the manager of a division or agency’s operation at the site of the proposed activity. If a nominee is appointed, an organisational chart should be provided showing the relationship of the nominee to the applicant and the operators.
Radiation Safety Officer
This is an individual appointed by the applicant to supervise radiation safety in relation to the facility, controlled apparatus and/or controlled material for which the licence is sought. This person must be technically competent in radiation protection matters relevant to the facility and any associated sources. Evidence of competency should be included with the application. If there is more than one radiation safety officer, the details of other radiation safety officers should also be provided.
Declaration
The declaration must be signed by the applicant or authorised person.
Section B: Kind of nuclear installation & type of authorisation
Indicate the kind of nuclear installation and type of authorisation that is sought.
Section C: Facility details
Provide a detailed description of the facility and its site including the site address. Include this information in the space provided or insert references to where this information can be found in supporting documents. The full title, version/edition, and approval date should be provided for all referenced documents.
The applicant must have plans and arrangements for managing the facility to ensure the health and safety of people and protection of the environment.
These should be a comprehensive program of policies and procedures that demonstrate how safety and security will be ensured. The content of these plans and arrangements will vary depending on the hazard and complexity of the facility.
There is no predetermined format for supplying this information. The applicant may either describe the plans and arrangements in the space provided or may reference suitable organisational documents. If the latter option is taken, the applicant must clearly indicate on the application form where the relevant information can be found within accompanying documents and provide the full title, version/edition, and approval date.
If there are sources associated with the proposed facility, the applicant should identify the relevant codes and standards and describe how compliance with these documents will be achieved. This information may be included in Section E of the application. Codes and standards applicable to each kind of source can be found here.
ARPANSA publishes information about international best practice (IBP) with links to various international standards that may be relevant to the proposed facility. Applicants should identify relevant IBP and describe how this will be implemented or taken into account.
Effective Control Arrangements
The applicant must demonstrate how he/she or the nominee will establish and maintain effective control over the facility. This should cover issues such as organisational arrangements, management systems and resources.
Safety Management Plan
The applicant must describe the administrative arrangements for managing the safety of the facility and any associated sources. This should cover issues such as safety culture, safety of premises and equipment, competency and training, incidents, auditing and record keeping.
The radiation protection plan should cover issues such as principles of radiation protection, planning and design of the workplace, classification of work area, local procedures, radiation monitoring of individuals and the workplace.
In addition, the applicant is responsible for ensuring that arrangements are implemented for the appointment of a suitably qualified radiation safety officer and/or radiation safety committee as appropriate. The applicant must provide information about the qualifications and experience of such persons and the arrangements in place for their continued competency.
Radioactive Waste Management Plan
A full description and anticipated amounts of any radioactive wastes, including discharges arising from the proposed conduct and the arrangements for the safe handling, treatment, storage and disposal of any such waste should be set out in a radioactive waste management plan.
Arrangements for the security of the facility and any associated sources to prevent theft, damage or unauthorised access must be provided. These arrangements should demonstrate how the security of the facility and any associated sources will be maintained and how periodic inventory checks will be undertaken to confirm that all sources are secure and in their assigned location.
Emergency arrangements should be developed for all foreseeable emergencies such as dispersion of materials, over-exposure of operators, or theft or loss of controlled material. The arrangements should include the responsibilities of all parties in the event of an emergency, contact arrangements, emergency procedures, emergency equipment and reporting arrangements. Where necessary, arrangements for involving external agencies such as police and other emergency services should be included. The level of detail should be commensurate with the hazard of the facility.
The plan should include arrangements for testing the emergency arrangements through regular reviews and exercises, and rectifying any deficiencies found in the plan.
Arrangements should be developed for the protection of wildlife populations and ecosystems in parallel with radiation protection of people, consistent with international best practice. The arrangements should include identification of all potential exposure scenarios and pathways to the environment and affected biota with environmental radiological assessments of wildlife in their natural habitats based on the concept of reference organisms.
Arrangements should be developed that demonstrate adequate planning for decommissioning to protect workers, the public and the environment. While most decommissioning activities take place in the final phase of a facility’s lifecycle, decommissioning should be considered as early as possible. An initial decommissioning plan should be developed at the design stage and periodically updated throughout subsequent life stages. The objective is to develop a final plan to be submitted when applying for authorisation to decommission the facility.
Applicants should provide additional information as shown in the table in section 46 of the Regulations specific to the type of authorisation sought.
Applicants should enter the information in the space provided or state clearly where this information can be found in the accompanying documentation. The full title, version/edition, and approval date should be provided for all referenced documents.
Applicants should complete the section(s) corresponding to the type of authorisation sought.
Section G: Associated sources
Sources that are part of, used in connection with, produced by, incorporated in, stored in, or disposed of in, a facility do not need a separate source licence but must be authorised by the facility licence.
Not all facilities have associated sources but where they do, this should be indicated in Section G of the application. A common type of source used in facilities is a calibration source. For sealed sources, a copy of any source certificate should be provided.
Section H: Source details
The details of any sources associated with the facility must be recorded in a source inventory workbook (SIW). This is the form approved by the CEO for maintaining source records. The SIW template is available here.
An explanation of terms and required information appears in the first worksheet of the SIW. If in doubt, contact ARPANSA for advice. The completed SIW should be submitted with the application.
Section I: Matters to be taken into account by the CEO
Subsections 32(3) and 33(3) of the Act require the CEO to take into account international best practice in relation to radiation protection and nuclear safety when making a decision whether to issue a licence. The CEO must also take into account the matters prescribed in section 53 of the Regulations.
Provide information on these matters in Section I of the application form.
International best practice in radiation protection and nuclear safety
Describe how international best practice (IBP) has been considered in relation to the facility relevant to the type of authorisation sought.
Each element of the proposed activity should be researched to determine what can be regarded as international best practice. Undertaking research and benchmarking exercises are useful ways to establish IBP. Implementation of relevant national and international codes and standards is considered a demonstration of best practice.
Agencies such as the International Atomic Energy Agency (IAEA) or the Nuclear Energy Agency are useful resources, particularly in relation to safety assessment and stakeholder involvement. The IAEA standards and recommendations have been developed by consensus of member countries and represent the distillation of best practice of their cumulative radiation and nuclear safety experience.
Provide information to demonstrate that the proposed conduct can be undertaken without undue risk to the health and safety of people and the environment. This should include evidence that the radiation risks to people and the environment arising from the proposed conduct have been fully assessed, including the probability and magnitude of potential exposures arising from incident scenarios and abnormal occurrences.
Net benefit
Provide information to demonstrate that the proposed conduct produces sufficient benefit to individuals or to society to offset the radiation harm that it might cause, taking into account social, economic and other relevant factors; that is, the applicant must justify the conduct and demonstrate a net benefit from it.
Optimisation of protection
Provide information to demonstrate that protection has been optimised. The level of protection should be the best under prevailing circumstances and should provide for an adequate margin of benefit over harm. Information should show that the likelihood of incurring exposures, the number of people exposed and the magnitude of exposures are as low as reasonably achievable, having regard to economic and societal factors. Information such as actual dose information, including dosimeter readings and surveys or sample dose calculations or both could be provided for this purpose.
Technical, human and organisational factors
Provide information to demonstrate that interactions between technical, human and organisational factors have been considered in the management of safety.
Human factors involve understanding human capability and limitations in operational and maintenance roles relating to the nuclear installation. There are a variety of human factors assessments that can be used to both understand and demonstrate the management of safety critical risks.
Organisational factors are aspects of the organisation that facilitate performance (in safety), eg. culture, safety management systems, leadership, resilience, defence-in-depth. Organisational factors can be addressed through a variety of self-reflective practices and systemic design.
Technical factors include the design, operation and maintenance of equipment, machinery and tools. It is important the organisation thinks about the ways in which humans will respond, adapt, and learn from organisational and technical factors.
Provide information to demonstrate that the applicant has the capacity to comply with the Regulations and licence conditions that would be imposed under section 35 of the Act.
Evidence of compliance with similar legislation such as that administered by Comcare or the Australian Safeguards and Non-Proliferation Office (ASNO) may be useful for this purpose. A current ARPANSA licence holder may refer to their compliance history.
Provide information to demonstrate that there are sufficient financial and human resources to safely undertake the proposed conduct.
Authorised signatory
The application must be signed by an office holder of the applicant or a formally authorised person. An office holder is the Secretary, Chief Executive Officer or an equivalent person of the Department or entity that is named as the applicant. Where a person authorised by an office holder of the applicant signs the application, a copy of the instrument of authorisation must be provided.
Checklist
A checklist is provided to confirm the application is complete.
Application fee
Refer to section 49 of the Regulations to determine the appropriate application fee. The fee must be received before the application can be assessed. Accepted payment methods are EFT, credit card or BPAY – please see payment methods.
When your application is submitted it will be examined to see if all the necessary information is included, if it is properly signed, if the correct application fee has been paid, and if a version of the application has been provided for public review. If so, you will receive an acknowledgment email. If any of the basic information is missing you will be contacted for further information or in some cases the application and fee may be returned.
As soon as practicable after receiving your application, and after confirming it is complete, the CEO is required by section 48 of the Regulations to publish a notice in a national daily newspaper and on ARPANSA’s website, stating the intention to make a decision on the application. The public version of the application will be published with the notice. The CEO will include in the notice:
an invitation to people and bodies to make submissions about the application
a period for making submissions
procedures for making submissions
Your application will then be assigned to a regulatory officer. The regulatory officer will discuss and agree a time with you to complete the assessment.
The regulatory officer will review all the information and consider the claims, evidence and arguments presented. Where matters require clarification, the regulatory officer will contact you or your nominee. The regulatory officer may also consider that an inspection or site visit is necessary and will contact you to arrange.
The officer will then prepare a regulatory assessment report to document the review. The content of any submissions made by members of the public about the application will be addressed in the report.
The assessment report will make a recommendation to the CEO about whether to issue a licence and may recommend licence conditions to be imposed under section 35 of the Act. The assessment report undergoes a rigorous review and approval process prior to being sent to the decision maker with all relevant documentation.
You will be advised in writing of the decision. The CEO may also publish a ‘statement of reasons’ for the decision on this website.
Detailed information about how ARPANSA undertakes assessments can be found in our Review and Assessment Manual on the 'how we regulate' page.
Under section 37 of the Act, a licence may be issued indefinitely or for a specified period. When issued a licence remains in force until it is cancelled or surrendered, or the specified period has elapsed.
Appealing a licence decision
Section 40 of the Act describes the rights of review available to eligible persons in respect of licence decisions made by the CEO. The following decisions are reviewable:
to refuse to grant a licence
to impose conditions on a licence
to suspend a licence
to cancel a licence
to amend a licence
not to approve the surrender of a licence
to issue a licence for a particular period, rather than for a longer period or indefinitely
not to extend the period for which a licence was issued
An eligible person in relation to a decision to refuse to grant a licence means the person who applied for the licence, and in relation to any other licence decision, it is the licence holder.
Review by the Minister
Should an applicant wish to have a licence decision reviewed, the applicant may request the Minister for Health to review the decision. The request must be in writing and be given to the Minister within 28 days of the making of the licence decision.
If a request for review is lodged, the Minister must reconsider the licence decision and confirm, vary or set aside the decision.
The Minister is taken to have confirmed the licence decision if the Minister does not give written notice within 60 days of the request.
Review by the Administrative Review Tribunal (ART)
An application may be made to the ART for review of a decision of the Minister.
This Regulatory Guide has been prepared to advise potential Commonwealth applicants, the public, and other stakeholders of the issues that will have to be addressed by an applicant when applying for a licence under the ARPANS Act to prepare a site for a controlled facility. It describes objectives for protection of human health and of the environment, drawing upon international best practice in relation to radiation protection and nuclear safety. I may decide to issue a licence authorising an applicant to prepare a site for a controlled facility only if the applicant demonstrates that the proposed facility will achieve the required level of radiation protection. The application should provide enough information to demonstrate that the facility can operate safely under all foreseeable circumstances. This Regulatory Guide is an update of the draft 1999 Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) Regulatory Guidance. It has been finalised after consideration of comments received during stakeholder consultation that occurred in the production of this Guide.
Carl-Magnus Larsson
CEO of ARPANSA
August 2014.
1. Introduction
1.1 Purpose and Structure of this Regulatory Guide
This Regulatory Guide is directed to Commonwealth entities applying for a licence under the Australian Radiation Protection and Nuclear Safety (ARPANS) Act 1998 (Cwth 1998) to prepare a site for a controlled facility, and to other stakeholders including the public, to:
assist in understanding the overarching statutory considerations and how the application will be assessed by the regulatory body
assist in understanding the requirements for the content of an application and to address the question “what is required?” in the application process
provide guidance based on national and international best practice for meeting the requirements and attaining high levels of safety and security.
The relevant Australian regulatory and safety standards framework is summarised in this introductory chapter (Part 1).
Parts 2 and 3 of the Regulatory Guide, ‘Requirements for Siting a Controlled Facility’, present:
the requirements from Australian standards and codes of practice that are mandated in legislation
additional guiding principles based on international best practice that establish the expectations of the CEO of ARPANSA for the protection of people and the environment.
Parts 4 and 5, ‘Technical Aspects of Site Selection’, provide guidance from international best practice for consideration by the applicant in meeting the relevant requirements. Some guidance on the system for protection of human health and the environment is presented in Annex A1. This Regulatory Guide replaces the draft Regulatory Guide RG-4 Criteria for the Siting of Controlled Facilities (ARPANSA 1999).
1.2 Scope
This Regulatory Guide draws together the essentials (requirements) that are set out in the ARPANS Act, Regulations and relevant national codes, and presents advice (guidance) to inform potential applicants seeking regulatory approval to site a controlled facility. The Guide, in setting out international best practice and the requirements established in legislation, does not set any new requirements.
The guidance presented here is generally applicable to the siting of all controlled facilities in Australia. Controlled facilities are defined in Section 13 of the ARPANS Act as:
(a) a nuclear installation; or
(b) a prescribed radiation facility.
A nuclear installation defined in Section 13 means any of the following:
(a) a nuclear reactor for research or production of nuclear materials for industrial or medical use (including critical and subcritical assemblies)
(b) a plant for preparing or storing fuel for use in a nuclear reactor as described in paragraph (a)
(c) a nuclear waste storage or disposal facility with an activity that is greater than the activity level prescribed by regulations
(d) a facility for production of radioisotopes with an activity that is greater than then activity level prescribed by regulations made for the purposes of this section.
A prescribed radiation facility is defined in Regulation 6 of the Australian Radiation Protection and Nuclear Safety Regulations 1999 (ARPANS Regulations). The definition includes the following types of facilities:
(a) certain particle accelerators
(b) certain irradiators used to deliver very high doses of ionizing radiation to material
(c) facilities (other than nuclear installations) used for the production, processing, use, storage, management or disposal of certain sealed and unsealed sources.
The Regulatory Guide: Licensing of Radioactive Waste Storage and Disposal Facilities v2 (ARPANSA 2013a) should also be referred to for the siting of waste storage and disposal facilities, as this guide provides specific guidance on matters that may not be covered in detail here.
1.2.1 Requirements and Guidance
In this Regulatory Guide, a requirement is something that is established by the ARPANS Act or the ARPANS Regulations. Specific requirements are stated in relevant national codes referred to in this Guide. In this context, the word ‘must’ is used to indicate that the particular requirement is essential.
Under Section 32(3) of the ARPANS Act, the CEO of ARPANSA is required to take into account relevant international best practice in relation to radiation protection and nuclear safety in deciding whether to issue a facility licence. In International Atomic Energy Agency (IAEA) safety standards, the Safety Requirements, which flow from the Fundamental Safety Principles (IAEA 2006), provide international best practice requirements to be met to ensure the protection of people and the environment, both now and in the future. These requirements are expressed as ‘shall’ statements together with statements of associated conditions to be met. Experience and expertise from other countries and international organisations should also be considered when determining what constitutes international best practice. Guidance is practice-specific advice on best practice and on how to comply with the requirements. This advice is generally based on an international consensus on the measures recommended. In general, the guidance presented in this Regulatory Guide reflects national and international best practice to help users of this document to attain high levels of safety and security. The guidance is expressed as ‘should’ statements. The advice is not mandatory, and alternative means are acceptable so long as safety and security objectives are met.
1.3 Legislative and Regulatory Framework
The regulatory environment in the Commonwealth of Australia for radiation safety and security embraces the following principles:
the prime responsibility for safety must rest with the person or organisation responsible for facilities and activities that give rise to radiation risks. This is the first principle of the IAEA Fundamental Safety Principles (IAEA 2006), and of the new draft Australian Fundamentals: Protection Against Ionising Radiation (ARPANSA 2014a).
the regulator, ARPANSA, is entirely separate from the proponent and/or operator of a controlled facility
international best practice will inform regulatory decisions and guidance on how to achieve the required safety and security outcomes
consultation with stakeholders, including the public and relevant governments, will be an integral part of the regulatory and licensing processes. Stakeholders are regarded as an asset who will contribute knowledge to the process. The role of stakeholders and their interaction with the regulator will be to ensure the most informed decisions and best possible outcomes.
1.3.1 The ARPANS Act and Regulations
The Commonwealth legislation relevant to the regulation of radiation and nuclear activities undertaken by Commonwealth entities are:
Australian Radiation Protection and Nuclear Safety Act 1998 (Cwth 1998)
Australian Radiation Protection and Nuclear Safety Regulations 1999 (Cwth 1999a).
The object of the ARPANS Act is to protect the health and safety of people and to protect the environment from the harmful effects of radiation. An application to site a controlled facility must address all of the relevant matters specified in the ARPANS Act and Regulations as well as providing any additional relevant information requested by the CEO of ARPANSA.
1.3.2 Matters to be Considered by the CEO
Subsection 32(3) of the ARPANS Act states:
‘In deciding whether to issue a licence under subsection (1), the CEO must take into account the matters (if any) specified in the regulations, and must also take into account international best practice in relation to radiation protection and nuclear safety.’
Regulation 41 specifies the matters which the CEO must take into account when assessing a licence application. These include:
the content of any submissions made by members of the public about the application
whether the information establishes that the proposed conduct can be carried our without undue risk to the health and safety of people, and to the environment; • whether a net benefit from carrying out the conduct relating to the controlled facility has been demonstrated (which in the case of waste management facilities, may involve a progressive and systematic reduction of hazards)
whether the applicant has shown that the magnitude of individual doses, the number of people exposed, and the likelihood that exposure will happen, are as low as reasonably achievable, having regard to economic and social factors
whether the applicant has shown a capacity for complying with the ARPANS Regulations.
When taking this last point into account, the CEO may consider whether the applicant has sufficient resources (competence, funding, staff and other resources necessary to achieve the outcomes) available over the lifetime of the proposed facility.
Sub-regulation 40(2) of the ARPANS Regulations states that, as soon as practicable after receiving an application for a facility licence, the CEO must publish a notice in a daily newspaper circulating nationally, and in the Gazette, stating that the CEO intends to make a decision on the application. If the licence application relates to a nuclear installation, then the CEO must also include in the notice:
an invitation to people and bodies to make submissions about the application
a period for making submissions
procedures for making submissions.
1.3.3 CEO’s Guiding Principles
Regulation 39 and Part 1 of Schedule 3 to the ARPANS Regulations specify the information that the CEO of ARPANSA may require from applicants for a facility licence. ARPANSA’s application form for a facility licence requires the relevant information in Part 1 of Schedule 3 to the ARPANS Regulations to be provided. This may include information about other relevant matters. This additional information, based on international best practice, is presented in this Regulatory Guide as guiding principles. These guiding principles represent the expectations of the CEO in assessing the completeness of any licence applications submitted to ARPANSA. It is important to understand the distinction between a regulatory requirement and an expectation. Applicants cannot be made to ‘comply with’ international best practice until such time as it is legally applied to them through licence conditions imposed by the CEO. That does not happen until the licence is issued. Through this Regulatory Guide however, ARPANSA is indicating where more detail in an application will be expected by the CEO based on international best practice. Under the ARPANS Act, a licence that is issued by the CEO of ARPANSA is subject to conditions in Section 35 of the Act, conditions prescribed in the ARPANS Regulations (Part 4, Division 4), conditions imposed by the CEO at the time the licence is issued and any condition imposed by the CEO under subsection 36(2) after the licence is issued.
1.3.4 Relevant National Codes, Standards and Guides
Regulation 48 requires licence holders to comply with the following recommendations and codes of practice when dealing with controlled materials, apparatus and facilities, including disposal of controlled material and apparatus:
the Code of Practice for the Security of Radioactive Sources (ARPANSA 2007);
the Recommendations for Limiting Exposure to Ionizing Radiation and National Standard for Limiting Occupational Exposure to Ionizing Radiation (ARPANSA 2002);
the Code of Practice for the Safe Transport of Radioactive Material (ARPANSA 2008);
the Code of Practice for the Disposal of Radioactive Wastes by the User (NHMRC 1985)
the Code of Practice for the Near-Surface Disposal of Radioactive Waste in Australia (NHMRC 1992).
Other relevant Australian requirements and guidance are available in:
the National Directory for Radiation Protection (NDRP, ARPANSA 2011)
Holistic Safety Guidelines (ARPANSA 2012a).
1.3.5 Environmental Protection and Biodiversity Conservation Act (EPBC Act)
An application to prepare a site for a controlled facility could, under Sections 21 and 22 of the Environment Protection and Biodiversity Conservation(EPBC) Act 1999 (Cwth 1999b), constitute a ‘nuclear action’ and require approval from the Environment Minister, if the ‘nuclear action’ has, will have or is likely to have, a significant impact on the environment. Nuclear actions should be referred to the Environment Minister and may have to undergo an environmental assessment and approval process.
Applications for approval under the EPBC Act will generally precede a licence application under the ARPANS Act. The need for a referral under the EPBC Act and the timing for submitting a referral should be discussed with the Department of the Environment early in the planning process. More information on the approval process under the EPBC Act is provided on the Environment Department’s website: www.environment.gov.au/epbc/protect/nuclear.html.
1.4 Flow chart of siting process
Figure 1 provides an overview, albeit simplistic, of the siting process. It is important to note that the highest-ranked site may not be the most plausible site for various reasons. If a rigorous timeline is involved in the project delivery, then several well-ranked sites may be short-listed for simultaneous site characterisation to minimise potential delays, with the best being chosen through that process. More details are provided in the following sections.
Figure 1. Flow chart showing the decision process, proceeding from identification of multiple potential sites, the ranking of those sites, characterisation of preferred site leading to the licence application to site the controlled facility (adapted from IAEA 2013a).
Requirements for Siting a Controlled Facility
2. The Licensing Process
2.1 Staged Licensing Approach
The staged licensing process follows from Section 30 of the ARPANS Act. Part 1 of Schedule 3 of the ARPANS Regulations prescribes the information that the CEO may require from an applicant for each type of authorisation. The staged licensing approach is consistent with international best practice. The stages of the licensing process for a controlled facility may include:
licence application to prepare a site (including conceptual facility design)
licence application to construct
licence application to possess or control
licence application to operate
licence application to decommission, dispose of, or abandon (close) a facility.
It should be noted that whilst the overall process is staged, there is strong linkage between each individual licence application. The licence application for each stage needs to be forward looking and contain sufficient information on the safety and security aspects of subsequent stage(s), to allow for an informed decision to be made by the CEO. Under some circumstances, an applicant may choose to submit applications for more than one licence simultaneously. The application to prepare a site for a controlled facility is expected to include details of the conceptual design, as well as a preliminary safety case and other aspects as further detailed in this Regulatory Guide. The application should provide enough information to demonstrate that the facility can operate safely under all foreseeable circumstances. As the process proceeds through the various stages, the safety case and accompanying safety assessment will develop accordingly. The staged approach will allow for continuous improvement in design, operation and safety throughout the lifetime of the facility. ARPANSA recognises the importance of gaining community support during all phases of the licensing process. Experience has shown that sound technical assessments alone are generally insufficient to ensure successful implementation. As already stated above in Section 1.3, communication and consultation with stakeholders is crucially important in building trust and confidence in the regulatory process. Guidance on effective communication and consultation, and the role of the safety case in dialogue with the public and in building confidence in the safety of the facility, is presented below.
2.2 Content of the Application – Overview
Licence applicants need to complete an application form for either a prescribed radiation facility or nuclear installation, depending on the activity levels of the controlled material in the facility as calculated under the provisions in Regulations 7, 8 and 11 of the ARPANS Regulations. Application forms and general regulatory guidance for licence applications are available for download from the ARPANSA website: www.arpansa.gov.au/Regulation/guides.
Section 34 of the ARPANS Act requires an application for a licence to be in a form approved by the CEO and be accompanied by such fee as is prescribed by the regulations. Regulation 39 of the ARPANS Regulations specifies the information and documents that the CEO of ARPANSA may require to be provided by an applicant/proponent.
While the format of the application is a matter for the applicant, each of the elements needs to be addressed to meet the requirements of the ARPANS Act, the ARPANS Regulations and all relevant regulatory guidelines published by ARPANSA. A graded approach should be used when developing the application, such that the level of detail included is consistent with the magnitude of the possible radiation risks arising from the proposed facility. The application should be written so that the application and associated documents can be independently assessed. To this end, all sources of information need to be appropriately referenced.
In addition to the ARPANS Act and Regulations, the following guidance documents are available on the ARPANSA website for licence applicants:
Regulatory Assessment Principles for Controlled Facilities (ARPANSA 2001a);
Regulatory Assessment Criteria for the Design of New Controlled Facilities and Modifications to Existing Facilities (RB-STD-43-00 Rev 1, ARPANSA 2001b);
Regulatory Guide: Plans and Arrangements for Managing Safety (ARPANSA 2013b);
Regulatory Guide: Applying for a Facility Licence for a Nuclear Installation (ARPANSA 2012b); and
Regulatory Guide: Applying for a Facility Licence for a Prescribed Radiation Facility (ARPANSA 2012c).
The regulatory assessment principles detail how the issues of safety culture, safety analysis, and defence-in-depth should be addressed in a licence application. They are primarily written for ARPANSA assessors, but may also assist licence applicants or operators in the preparation of the safety analysis report (an element of the safety case) which accompanies the licence application for a controlled facility. The regulatory guide on plans and arrangements provides guidance on the information to provide for protection of human health and the environment when addressing Part 1 of Schedule 3 to the ARPANS Regulations.
These are:
effective control
safety management
radiation protection
radioactive waste management
security
emergency.
2.3 Licence to Prepare a Site for a Facility (Including Conceptual Design)
The application for a licence to prepare a site for a controlled facility must comprise, as a minimum, the general information referred to in items 1 to 4 of Part 1 of Schedule 3 to the ARPANS Regulations and the specific information referred to in items 5 to 7 of Part 1 of Schedule 3, which specify additional requirements to be met by an application seeking authorisation for preparing a site for a controlled facility. These additional requirements are:
a detailed site evaluation establishing the suitability of the site
information describing the characteristics of the site, including the extent to which the site may be affected by natural and man-made events
any environmental impact statement (EIS) requested or required by a government agency, and the outcome of the environmental assessment.
The wording of these additional requirements is taken from the current ARPANS Regulations. While applications for approval under the EPBC Act will generally precede a licence application under the ARPANS Act, it is acknowledged that the outcome of an EIS assessment may follow a siting licence application but would be expected prior to a decision being made on that licence. These requirements are in line with the IAEA Safety Requirements for site evaluation for nuclear installations.
The IAEA Safety Requirements document titled Site Evaluation for Nuclear Installations (IAEA 2003) states:
Proposed sites shall be adequately investigated with regard to all the site characteristics that could be significant to safety in external natural and human induced events.
The applicant is expected to supply, in addition to details on the site characteristics, information on:
the conceptual design for the facility, focusing on how the design impacts safety and security at and around the preferred site;
the transport system to and from the facility (modes of transport, transport routes, distances involved, current traffic/transport infrastructure conditions and usage and projected future traffic flows/usage for the life of the project and risk analysis thereof, and related safety and security considerations);
the beginnings of a decommissioning plan that will develop through the construction and operation phases of the facility. The IAEA Safety Requirements: Decommissioning of Facilities (IAEA 2014a) state that during siting, decommissioning is under ‘consideration’, and planning for decommissioning shall start during the design phase
the availability of resources over the lifetime of the proposed facility, including for decommissioning.
Some of these aspects (e.g. as regards facility design and decommissioning plan) are expected to develop as the project matures, and in their developed state must form part of the licence applications for future stages including the licence applications to construct or to operate the controlled facility.
3. Requirements and Guiding Principles
3.1 Demonstrating Radiation Protection
An application for a licence to site a controlled facility should contain enough information to demonstrate that there is a reasonable likelihood that the proposed facility:
can be sited, constructed, operated and closed safely
will meet all relevant legislative and regulatory requirements relating to radiation protection under all reasonably foreseeable circumstances.
It is recognised that some aspects related to this assessment may not be fully detailed at the siting stage; however, the assessment should consider reasonable values for materials that are likely to be handled at the site and any exposure scenarios that are likely to occur for this type of facility. Where site specific data are unavailable, data from similar sites and facilities could be used.
Additional information on the radiation protection principles and regulatory requirements that should be considered are provided in the national standard Recommendations for Limiting Exposure to Ionizing Radiation (1995) and National Standard for Limiting Occupational Exposure to Ionizing Radiation (2002) (ARPANSA 2002) and in Annex A1 of this guide.
3.2 Safety and the Safety Case
The requirements from international best practice to include a safety assessment and a developed safety case in an application for a licence to prepare a site for a controlled facility are implicit throughout the IAEA Safety Requirements.
The ARPANS Act and Regulations contain no specific requirement for the preparation of a safety case based around safety assessment principles for a controlled facility. However, based on international best practice requirements, a guiding principle of the CEO is that the applicant shall demonstrate that any proposed facility will meet the required level of protection by carrying out and presenting a safety case that draws upon the organisational and technical arrangements put in place, the characteristics of the site, the design of the facility, including any engineered safety barriers, and the arrangements for its construction and operation. Guidance for developing a safety case in compliance with this principle can be found in Section 4.2 of this Regulatory Guide.
3.3 Demographic Considerations
Based on international best practice, a guiding principle of the CEO is that an applicant for any licence covered by this Regulatory Guide shall, as part of the licence application, address the impact of the facility on the community in which the facility is, or is to be situated. All relevant current and future societal aspects shall be considered including transport routes within Australia and public concerns regarding local transport conditions.
3.4 Consultation
The expectation of the CEO is that the proponent shall include, in the application, an account of public consultation that has occurred, if any, including information on the format of the consultation, issues raised in submissions and responses to issues raised A guiding principle of the CEO is that the applicant for a facility licence for a nuclear installation will conduct appropriate stakeholder and public consultation, following a graded approach, in order to enable stakeholders to contribute knowledge to the siting and design processes. This is in addition to the requirement under Regulation 40 for public consultation by the CEO.
3.4.1 Summary of Application in Plain and Non-Technical Language
A guiding principle of the CEO is that the proponent shall provide a summary of the licence application and the supporting safety case, in plain and non-technical language, in order to facilitate stakeholder interaction in the review by the regulator of the licence application. The summary shall provide enough information and be presented in a format suitable for all stakeholders to understand the scope and content of the application, facilitate communication between all interested parties and promote understanding of the impact of the facility among all stakeholders. This plain-language summary may take the form of an executive summary of the safety case. Consideration shall be given to ensure that those who do not use English as their first language are included in the consultation process. Where Aboriginal people are involved as stakeholders, the expectation of the CEO is that such information shall be provided in a culturally appropriate manner.
3.5 Quality Assurance
In keeping with the IAEA Safety Requirements, a guiding principle of the CEO is that an application for a licence to prepare a site for a controlled facility shall include relevant aspects of a quality assurance programme, consistent with the stage of the project. A comprehensive quality assurance programme shall be applied to all safety-related activities, structures, systems and components of the controlled facility. This includes all related activities, from planning through siting, design, construction, operation, the various steps in the safety assessment process, long-term recordkeeping and decommissioning.
3.6 Provision of Adequate Funding
The IAEA states in the General Safety Requirements: Governmental, Legal and Regulatory Framework for Safety (GSR Part 1, IAEA 2010a) that:
The regulatory process shall provide a high degree of confidence… [that] authorized parties have the human, organizational, financial and technical capabilities to operate facilities safely or to conduct activities safely under all circumstances until their release from regulatory control.
A guiding principle of the CEO, based on international best practice, is that a licence application to prepare a site for a controlled facility shall include evidence of the provision of adequate financial resources over the lifetime of the controlled facility.
3.7 Security
An application for a licence to prepare a site for a controlled facility must address all relevant security issues as required under the Code of Practice for the Security of Radioactive Sources (RPS 11, ARPANSA 2007).
If nuclear material is involved in the facility, then progressively through the licencing process, beginning with concept design, the security systems and infrastructure protecting the nuclear material will need to comply with the requirements of the Convention on the Physical Protection of Nuclear Material (IAEA 1979) and the IAEA guidance document Nuclear Security Recommendations on Physical Protection of Nuclear Material and Nuclear Facilities (IAEA 2011a). This is managed through permits issued under s13 of the Nuclear Non-Proliferation (Safeguards) Act 1987 (Cwth 1987), administered by the Australian Safeguards and NonProliferation Office (ASNO). Nuclear security requirements vary considerably depending on the types and quantities of nuclear material and in many cases will be met by security measures put in place for compliance with RPS 11 without further modification.
3.8 Safety and Security Culture
Based on international best practice, a guiding principle of the CEO is that an applicant for a licence to site a controlled facility covered by this Regulatory Guide shall, as part of the licence application, provide information upon which an assessment can be made of the adequacy of the safety and security culture of the applicant organisation. The required information shall demonstrate the commitment of senior management within the operator to safety and security, and the establishment and maintenance of an appropriate culture within the facility to be licensed. ARPANSA’s expectations and advice are presented in the ARPANSA document Holistic Safety Guidelines (ARPANSA 2012a). Some details of how holistic safety will be implemented by ARPANSA are available on the ARPANSA website: http://www.arpansa.gov.au/Regulation/Holistic/index.
Any proposed change in the operator over the lifetime of the facility would be subject to similar scrutiny by the regulator.
The IAEA General Safety Requirements: Governmental, Legal and Regulatory Framework for Safety (GSR Part 1, IAEA 2010a) state the following:
Requirement 1 dealing with National Policy - “In the national policy and strategy, account shall be taken of the following: ... The promotion of leadership and management for safety, including safety culture.”
Requirement 29 dealing with Inspections - “In conducting inspections, the regulatory body shall consider a number of aspects, including: ... safety culture.”
3.9 Emergency and Remediation Preparedness
Principle 8 of the IAEA Fundamental Safety Principles (IAEA 2006) states that:
All practical efforts must be made to prevent and mitigate nuclear or radiation accidents.
The purpose of the information presented in this Regulatory Guide is to assist in selecting a site that will minimise the likelihood of any radiation accident associated with a controlled facility in Australia. However, history has clearly demonstrated that nuclear and radiation accidents that affect public and environmental health do occur.
Schedule 3 of the ARPANS Regulations states that an emergency plan for the controlled facility is required as part of the licence application to site a controlled facility. Information that may be useful in preparing this plan is available in Intervention in Emergency Situations Involving Radiation Exposure (ARPANSA 2004), and Regulatory Guide: Plans and Arrangements for Managing Safety (ARPANSA 2013b).
A guiding principle of the CEO based on international best practice (Larsson 2013) is that an application for a licence to site a controlled facility shall, as part of the licence application, provide information on how the chosen site meets criteria for remediation preparedness. The licence application to site a controlled facility shall include consideration of how the site characteristics may impact emergency and accident-recovery preparedness. Demonstration of adequate preparedness to remediate the effects of any environmental contamination arising from a radiation accident, including in the transport of radioactive materials, shall include information on the following:
division of responsibilities in accident recovery, including the role of stakeholders
approaches to defining targets and end states
potential methods and technology available for environmental remediation.
The purpose of such remediation preparedness, as well as helping to build trust and provide assurance for relevant stakeholders, is the recognition within the international radiation safety community, based on lessons learned from past major nuclear accidents, that it is too late to begin planning for accident recovery after an accident has occurred.
3.10 Identification of Representative Individuals of the Public
The International Commission on Radiological Protection (ICRP), in their Publication 101a Assessing Dose of the Representative Person for the Purpose of the Radiation Protection of the Public (ICRP 2006a) states that:
Dose to the public cannot be measured directly and, in some cases, it cannot be measured at all. Therefore, for the purpose of protection of the public, it is necessary to characterise an individual, either hypothetical or specific, whose dose can be used for determining compliance with the relevant dose constraint. This individual is defined as the ‘representative person’. The Commission’s goal of protection of the public is achieved if the relevant dose constraint for this individual for a single source is met and radiological protection is optimised. In accordance with the ICRP recommendations (ICRP 2006a), the CEO has determined as a guiding principle that the goal of protection of the public is achieved if the relevant dose constraint for the appropriately characterised representative individual is met and radiological protection is optimised.
3.11 Protection of the (Natural) Environment
In order to demonstrate that the proposed conduct can be carried out without undue risk to the health and safety of the environment, a guiding principle of the CEO is that the applicant shall undertake a screening assessment of doses to wildlife (i.e. animals and plants living within their natural environment) in the vicinity of the controlled facility by use of one of the internationally accepted screening tools. If a screening assessment indicates that exposures to relevant wildlife in the natural environment are likely to be higher than the screening dose rate (defined within the range 5 to 10 μGy per hour, depending on the conservatism demonstrated and species affected), more detailed assessments of potential environmental impact shall be undertaken.
Technical Aspects of Site Selection
4. General Guidance
General guidance applicable to the siting of controlled facilities is presented in this Section.
The ARPANS Act requires that, in deciding whether to issue a licence, the CEO must take into account international best practice in relation to radiation protection and nuclear safety. The CEO therefore expects an applicant for a licence to have regard to and apply international best practice. The previous sections describe the sources of international best practice for radiation protection and nuclear safety that predicate the CEO’s requirements and guiding principles. The sections below provide further guidance on the use of international best practice in framing an application for a licence to prepare a site for a controlled facility.
It is envisaged that an application will be based on:
international best practice in radiation protection and nuclear safety;
the results of available research; and
studies and data specific to the facility as appropriate.
Any and all unknown variables or assumptions made in the application should be clearly stated and discussed. The extent to which the limitations, if any, of available information may influence the conclusions of the application should be discussed.
ARPANSA recognises that there may be a need to make use of material that is considered to be of a confidential nature, for instance information of a commercial nature or on security grounds. The applicant may request that such information not be included in any publicly available document. ARPANSA would generally take the view that, subject to national security considerations, all relevant information would be available to the state/territory government where the facility is located.
4.1 Guidance on the use of the Graded Approach
The amount of detail provided in an application to site a controlled facility should be determined using a graded approach. This means that the level of detail and resources used should be proportional to the assessed level of risk (safety and security). When assessing the level of risk posed by the proposed facility, the applicant should consider:
the hazards and complexities of the work that will take place at the facility
the types of materials that will be used or stored at the facility
the particular characteristics of the planned facility and proposed site
potential impacts to workers, the public and the environment
any other relevant factors.
The application should provide enough information to demonstrate that the facility can operate safely under all reasonably foreseeable circumstances. If the possible risks to human and environmental health are low, the application may be less detailed than for a facility with higher risks.
If the EPBC Act is triggered, the siting licence application is likely to contain a similar level of detail to the Environmental Impact Statement required by the EPBC Act. The EPBC Act will have required a comparative assessment of the zero option (i.e. status quo – continue practices as now). This comparison process should be extended to the radiological safety and security aspects in the licence application.
Additional information on the graded approach can be found in the IAEA Safety Glossary (IAEA 2007).
4.2 Relevant International Standards
During the past decades, the IAEA has led the development of an international regime on nuclear and radiation safety. This involves three key elements: legally binding international treaties; globally agreed international safety standards; and provisions for facilitating the application of those standards.
A prime objective of the IAEA is to foster internationally harmonised approaches to radiation and nuclear safety, and to promote international best practice. A principal mechanism for achieving this harmonisation has been the establishment of internationally agreed safety standards and the promotion of their global application.
4.2.1 IAEA Safety Fundamentals
The hierarchy of IAEA Safety Standards involves three levels, with the IAEA Safety Fundamentals at the top. The document Fundamental Safety Principles (IAEA 2006) sets out the fundamental safety objective (to protect people and the environment from harmful effects of ionising radiation) and ten associated safety principles.
4.2.2 IAEA Safety Requirements
Beneath the Safety Fundamentals are the Safety Requirements, comprising seven General Safety Requirements (GSRs) and other Specific Safety Requirements. This integrated set of Safety Requirements establishes the international consensus of standards that is required to be met to ensure the protection of people and the environment, both now and in the future, governed by the objective and principles of the Safety Fundamentals.
An application for a licence to prepare a site for a controlled facility should address all relevant requirements from the GSRs and from the IAEA Nuclear Safety Requirements document Site Evaluation for Nuclear Installations (NS-R-3, IAEA 2003).
NS-R-3 establishes the requirements for site evaluation for a nuclear installation. Its purpose is to establish criteria to ensure that site related phenomena and characteristics are adequately taken into account, that emergency plans can be implemented over the lifetime of the facility, and that site-related hazards are defined.
The siting process for a nuclear installation generally consists of an investigation of a large region to select one or more candidate sites (site survey), followed by a detailed evaluation of those candidate sites. NS-R-3 is primarily concerned with the latter stage. It encompasses site related factors, and site-installation interaction factors, that relate to operating and accident conditions, including those that could lead to emergency measures. NS-R-3 is concerned with the evaluation of those site related factors important for ensuring that the site–installation combination does not constitute an unacceptable risk to individuals, the population or the environment over the lifetime of the installation.
The site evaluation for a nuclear installation covers the selection, assessment, pre-operational and operational stages. The requirements established in NS-R-3 do not apply to the site selection stage, for which a different series of criteria may be used, including criteria that have little direct relevance to safety.
4.2.3 IAEA Safety Guides
Beneath the Safety Requirements is a suite of Safety Guides which are based on an international consensus and provide assistance on how to comply with the Safety Requirements. Many of these guides have been developed primarily for the siting of nuclear power plants; however, they also contain information highly relevant to the siting of other facilities. Those that have particular relevance to siting are listed here:
Draft Specific Safety Guide DS433: Site Survey and Site Selection for Nuclear Installations (IAEA 2013a).
Safety Guide: External Human Induced Events in Site Evaluation for Nuclear Power Plants (IAEA 2002a).
Safety Guide: Dispersion of Radioactive Material in Air and Water and Consideration of Population Distribution in Site Evaluation for Nuclear Power Plants (IAEA 2002b).
Safety Guide: Geotechnical Aspects of Site Evaluation and Foundations for Nuclear Power Plants (IAEA 2004).
Safety Guide: Seismic Hazards in Site Evaluation for Nuclear Installations (IAEA 2010b).
Safety Guide: Meteorological and Hydrological Hazards in Site Evaluation for Nuclear Installations (IAEA 2011b).
Safety Guide: Volcanic Hazards in Site Evaluation for Nuclear Installations (IAEA 2012a).
The Nuclear Safety Requirements standard Site Evaluation for Nuclear Installations (IAEA 2003) does not cover the initial stage of the siting process, i.e. the site survey, when studies and investigations at regional scale are performed to identify potential sites from which candidate sites are chosen. This is covered in the new draft Safety Guide DS433: Site Survey and Site Selection for Nuclear Installations (IAEA 2013a)
The objective of DS433 is to provide guidance on the siting of a nuclear installation, for meeting the safety objectives of the IAEA Safety Fundamentals and complying with the Safety Requirements NS-R-3. Recommendations on criteria and approaches are provided in DS433 in order to identify suitable sites for nuclear installations complying with established safety requirements. The Safety Guide also has the objective of providing guidance on establishing a logical process for siting and establishing a suite of preferred candidate sites any of which could be selected for the construction and operation of a nuclear installation.
Safety Guide DS433 does not provide guidance on the final evaluation or characterisation of a site nor establish an assessment of the site hazard for use in the design evaluation for licensing purpose.
As the site survey and selection process does not require a licence from the regulatory body, the Safety Guide DS433 also has an informative role to the regulatory authority. If it is concluded during detailed assessment that no engineering solutions exist to design protective measures against those external hazards that challenge the safety of the nuclear installation, or there are no adequate measures to protect the peoples against unacceptable radiological risk, the site is not suitable and is not licensable. The siting process is intended to reduce such a late unfavourable conclusion from a safety point of view. The radiological safety of selected sites will be confirmed during the detailed site assessment stage.
DS433 explicitly addresses the safety aspects of the siting process of nuclear installations. It is recognized that there are other aspects that play an important role in the siting process, such as security, technology, economics, land use planning, cooling water availability, non-radiological environmental impact, and socio-economic aspects including public opinion.
As the siting process progresses, more and more sites will be screened out until only a few sites remain and the importance of safety aspects will become more pronounced.
The separation between the investigation processes of site survey and site evaluation may not be very distinct and will depend on the methodology used. There is a transition between these two stages of work and DS433 addresses the process that eventually terminates with the selection of site(s) for one or more nuclear installations.
As well as considering the siting of nuclear installations at new sites, DS433 provides recommendations regarding the collocation of new installations at existing sites.
4.3 The Safety Case
Systematic and internationally recognised approaches have been developed for assessing the safety of radiation and nuclear facilities. These involve developing a safety case for a specific facility. IAEA standards describe the safety case as an integration of arguments and evidence that describe, quantify and substantiate the safety, and the level of confidence in the safety, of the facility
A safety case submitted to ARPANSA as part of a siting licence application for a controlled facility should include the following elements as appropriate:
a safety assessment;
provision for periodic safety reviews and ongoing review and update as necessary of the safety assessment;
stakeholder involvement;
demonstration of the competence and adequate resources of the proponent;
a quality management system; and
methods for mitigating the consequences of an event or accident.
The safety case and supporting safety assessment provide the basis for demonstration of safety and for licensing, and should evolve with the development of the facility. The safety case should assist and guide decisions on siting as well as design and operations. The safety case will also be the main basis on which dialogue with interested parties will be conducted and on which confidence in the safety of the facility will be developed.
4.3.1 Safety Assessment
Safety assessment is the systematic assessment of all aspects of a practice that are relevant to protection and safety. The safety assessment should be started during the siting and conceptual design phase and be updated as necessary over the lifetime of the facility in order to account for possible changes in site characteristics, modifications to design or operation, new technical developments and regulatory standards.
The primary purpose of the safety assessment is to determine whether an adequate level of safety is being achieved for a facility or activity. Safety assessment provides reasonable assurance that the facility complies with all applicable regulatory requirements.
As stated in the IAEA General Safety Requirements: Safety Assessment for Facilities and Activities (IAEA 2009):
Safety assessments are to be undertaken as a means of evaluating compliance with safety requirements (and thereby the application of the fundamental safety principles) for all facilities and activities and to determine the measures that need to be taken to ensure safety. The safety assessments are to be carried out and documented by the organization responsible for operating the facility or conducting the activity, are to be independently verified and are to be submitted to the regulatory body as part of the licensing or authorization process.
IAEA (2009) lists 24 requirements for performing the safety assessment and all that are relevant will be considered in the assessment of any licence application. Particular attention is drawn to Requirement 1: Graded Approach to Safety Assessment;
A graded approach shall be used in determining the scope and level of detail of the safety assessment carried out in a particular State for any particular facility or activity, consistent with the magnitude of the possible radiation risks arising from the facility or activity.
It is expected that the safety assessment will become more detailed and based on the developed design and actual constructed facility as the project proceeds through the application stages.
The application should contain or make reference to sufficient information from any documentation or studies undertaken to enable the safety case to be understood by ARPANSA assessors and members of the public from the application alone.The application should provide the necessary information to enable interested stakeholders to understand the safety case and supporting safety assessment relating to the choice of the site and the proposed development of the controlled facility, having regard to international best practice in relation to radiation protection and nuclear safety.
4.4 The Representative Individual
For the purpose of radiation protection of the public, a representative person is an individual, either hypothetical or specific, who is characterised to be representative of the more highly exposed individuals in the population. It is considered that protection of the public is achieved when the dose to the representative person is less than the dose constraint, and when radiation protection is optimised.
When considering dose to the representative person, the ICRP (2006) recommend that the assessment should:
account for all relevant exposure pathways
consider the spatial distribution of radionuclides to ensure that the most exposed population is included
base habit data on the exposed population, and ensure that these data are reasonable, sustainable and homogenous
apply dose coefficients according to specific age categories.
Additional guidance on the use of the ‘representative individual’ in assessing doses to the public is available in the ICRP Publication 101a Assessing Dose of the Representative Person for the Purpose of the Radiation Protection of the Public (ICRP 2006a).
4.5 Public and Stakeholder Consultation
If the application is to site a nuclear installation, the public and relevant governments will be invited to comment and make submissions on the application (as per Regulation 40 of the ARPANS Regulations). The licence application will be the principal source of information on the facility from which interested individuals and groups may gain an understanding of what is proposed and the applicant’s arguments for its safety and security.
While ARPANSA is responsible for the conduct of the public submissions process under Regulation 40 of the ARPANS Regulations, the applicant should, separately, take appropriate steps to ensure that procedures are established and implemented to make information on safety aspects of the licence application available to members of the public.
The IAEA General Safety Requirements: Safety Assessment for Facilities and Activities (IAEA 2009), Requirement 22, requires that, “the processes by which the safety assessment is produced shall be planned, organized, applied, audited and reviewed.” This international bestpractice requirement includes the expectation that details of the safety case for the facility are communicated to the stakeholders:
Consideration is also to be given to ways in which results and insights from the safety assessment may best be communicated to a wide range of interested parties, including the designers, the operating organization, the regulatory body and other professionals. Communication of the results from the safety assessment to interested parties has to be commensurate with the possible radiation risks arising from the facility or activity and the complexity of the models and tools used.
In essence, in order to build confidence in the safety case, the applicant should demonstrate that there has been sufficient early and ongoing stakeholder involvement throughout the safety case development process.
4.6 Protection of the (Natural) Environment
The natural environment refers to all physical, chemical and biological conditions within which wild plants and animals normally live. Radiation protection of the environment is specifically concerned with wildlife living within its natural environment. Agricultural plants and domestic animals are considered under the protection of people.
The general intent of radiation protection of the natural environment is to protect ecosystems against radiation exposure that would have adverse consequences for populations of species (ICRP 2007).
The radiological environmental assessment for wildlife should be as simple as possible, but as complex as necessary. A graded approach should be used. The assessment should consider the likely exposure scenarios and pathways, including transfer of radionuclides to wildlife for internal dosimetry calculations. It should also include a discussion of scenarios and assumptions, limitations in the methodology or data used, and uncertainties in results. Protection should be subject to a screening dose rate for wildlife which depends on the conservatism demonstrated by the proponent in the screening assessment and species affected. The screening dose rate is defined in the range 5 to 10 µGy/h.
If the screening dose rate is exceeded, then a more complex assessment should be made. A more complex assessment could use, for example, less conservative assumptions or site specific data obtained from an environmental monitoring program. ARPANSA is currently preparing a safety guide titled Radiation Protection of the Environment (ARPANSA 2014b) to provide additional guidance on these types of assessment.
The IAEA is currently drafting the Safety Guide Radiation Protection of the Public and the Environment (IAEA 2014c) which will provide general guidance on the application of the IAEA Safety Fundamentals (IAEA 2006) and requirements of the revised International Basic Safety Standards (IAEA 2014b) in relation to protection of the public and the environment.
Another IAEA Safety Guide under development, A General Framework for Radiological Environmental Impact Assessment and Protection of the Public (IAEA 2014d), will assist the production of a Radiological Environmental Impact Analysis to assess the radiological impact on the environment of facilities and activities for which a radiation safety assessment is required for purposes of compliance with given acceptance criteria.
4.7 Security
Certain types of radioactive materials pose a security threat. Examples are radioactive sources of high activity, spent nuclear fuel and residues from reprocessing of nuclear fuel. A valid concern is that terrorist or criminal groups could gain access to such material and use it with harmful intent. Consequently, there has been a global trend towards increased control, accounting and security of such materials to prevent this happening.
To address these issues, the IAEA provides guidance and recommendations through the Nuclear Security Series and direct contacts with Member States on the security of radioactive sources. The recommendations from these documents and services are based on a set of Fundamental Security Principles and a methodology that considers the consequences of security-related events with respect to the State’s assessment of the threat. They enable the establishment of physical protection criteria that are balanced, provide security-in-depth, and whose implementation is graded by the severity of consequence.
The application of nuclear security principles to siting and the early stages of design of controlled facilities has the potential to increase security, decrease operational impact, lower operating costs and allow for greater integration with safety and safeguards systems. The types and quantities of radioactive material being held will largely influence the nature and extent of the consequences that may arise from security-related events.
It is often the case that the set of measures taken to establish a safety envelope or system for a facility or activity, as established and maintained through the implementation of relevant safety requirements, is affected by or “intersects” with the security envelope/system established through implementation of the security requirements. This intersection of measures taken to ensure facility or activity safety and security is commonly referred to as the safety-security interface. At this intersection, the measures taken to ensure safety or security can be mutually beneficial to maintaining the respective safety or security system. At the same time, some measures taken for maintaining the safety system may be detrimental to maintaining the security system, and vice versa. The importance for identifying these system interfaces is to ensure that the licence applicant recognises those that are not mutually supporting for safety and security, and the need for taking further measures to ensure that the respective safety and security system integrity is maintained. Less important, but worth identifying and taking advantage of, are those measures that are mutually beneficial.
The licence application should provide adequate information on security-related aspects of the site itself, including, but not limited to, site characteristics, proposed design of the facility and passive barriers, and proposed active security provisions such as alarms and on-site guards, etc. Where a proposed facility is to be collocated with new or existing facilities, any specific security issues arising from the collocation should be taken into account in the site evaluation for the proposed facility. For example, the siting of a new facility near an existing site which has security requirements that could be compromised may require special considerations during later phases.
5. Guidance on Site Selection and Characterisation
Selection and characterisation of potential sites for a controlled facility is a multi-step process as shown in Figure 2. The first step is to evaluate possible sites against a set of screening criteria. The sites that survive this process should then be evaluated and ranked against more rigorous selection criteria. The sites still under consideration will then undergo a detailed safety and impact assessment to determine whether the facility is likely to remain in compliance with legislative and regulatory requirements under all reasonably foreseeable circumstances. The conceptual design of the controlled facility should be taken into account during the site selection process in order to assess the potential radiological impact of the proposed facility.
Stakeholder involvement in the site selection process is extremely important, both in terms of general communication and also in terms of building confidence in the process.
While international best practice is to consider alternative sites, it is noted that in many cases for pragmatic reasons only one site is considered for full site evaluation
Figure 2: Flow chart showing the general steps involved in site selection and characterisation (adapted from IAEA 2013a).
5.1 Selection of potential sites
Initially, if there are multiple potential sites in the region of interest, these should be identified and assessed against the screening criteria.
5.1.1 Screening criteria
Screening criteria should be generic rather than site specific, and should be designed to eliminate sites that are obviously unsuitable from further consideration. The criteria should consider safety related aspects as well as any other aspects that would exclude a site from consideration.
Screening criteria should include:
site and regional characteristics that could obviously compromise safety
current and anticipated land use
cultural significance
economic significance
demographic considerations.
Screening criteria should be developed by the proponent, following international best practice and in consultation with stakeholders. Further information on the development of screening criteria can be found in the draft IAEA Safety Guide DS433 (IAEA 2013a).
5.2 Ranking of sites
Candidate sites should be compared and ranked in order of their attractiveness as the facility site. Selection criteria for ranking of sites should be more detailed than screening criteria and should be chosen to optimise the safety and efficiency of the proposed facility. Selection criteria may be site specific, particularly with respect to demography or environmental sensitivity issues, and will often include relevant social issues as well as technical/safety matters.
Criteria for ranking sites should be developed by the proponent in consultation with the regulator. Further guidance on the process of ranking potential sites is available in the draft IAEA Safety Guide DS433 (IAEA 2013a).
5.3 Evaluation of potential sites
The identification of the characteristics of the preferred site is an essential part of the site selection and evaluation process. There are several categories of site characteristics, including:
those that may affect the preparation of the site and the design of the proposed facility;
those that are needed to sustain the normal operation of the proposed facility;
those that provide input for the assessment of the radiological impact of a proposed controlled facility on the population and the environment; and
those that provide input for evaluating the feasibility of onsite and offsite emergency intervention and remediation preparedness following any accident.
Some characteristics (for example, availability of support services) may appear in more than one category.
The site characteristics (other than facility design) that could affect the assessment of the radiological impact of the proposed facility can be divided into three categories: features, events and processes. These are discussed in more detail in the following three sections.
Where relevant, the identified site characteristics should be assigned a frequency and severity, including uncertainties, from historical records. Where site specific frequency and severity data are unobtainable, data from other regions that are sufficiently relevant to the region of interest should be used. A graded approach should be used to determine the degree of detail required for the identification and description of site characteristics.
The information that should be considered for site characterisation is outlined in the following sections. This list is not exhaustive, and any additional information specific to the site under consideration should also be discussed.
5.3.1 Features
The features of a site that may affect the radiological impact of the proposed facility include geology, geomorphology, meteorology, and demography. Geology Geological information should include consideration of the following factors for both normal and extreme conditions (such as earthquakes and floods):
surface faulting
volcanic activity
landslides
permafrost
erosion processes
subsidence and collapse due to underground features
soil types and depths
rock types:
load bearing capacity
presence of fracturing
stability
liquefaction potential
groundwater levels and regimes.
Additional guidance can be found in the IAEA Safety Guide: Geotechnical Aspects of Site Evaluation and Foundations for Nuclear Power Plants (IAEA 2004).
Geomorphology
This includes geographical information about:
surface water features such as creeks and rivers
topography, such as mountains, valleys
any other features that could affect the diffusion or dispersion of airborne effluents or act as ultimate heat sinks.
Ecology
This includes information and details related to:
vegetation types and abundance
wildlife
threatened and endangered species.
Meteorology
Information on site-specific meteorological phenomena is essential for both site selection and facility design and for understanding the consequences of the releases of radioactive material at the site. Meteorological information should include data for both average and extreme conditions related to:
historical records of wind speed and direction, air temperature, precipitation (rain, snow, sleet), humidity, pressure, frontal systems
details of daily and seasonal and inter-annual variability
potential changes in climate and weather over the lifetime of the controlled facility.
Additional guidance can be found in the IAEA Safety Guide: Meteorological and Hydrological Hazards in Site Evaluation for Nuclear Installations (IAEA 2011b).
Demographics
This information should include:
present and projected population distributions in a form suitable for use in radiological assessments
details of transient, part-time or seasonal occupation, with best estimates of occupation time and numbers of occupants
details of present and projected land use (includes agriculture, livestock, dairy farming, wetlands, commercial, residential and recreation land and water use)
details of local diets, and locations and amounts of water used for drinking, industrial and recreational purposes
details of special needs groups (e.g. hospitals, aged care homes, prisons, child care facilities).
More detailed guidance can be found in the IAEA Safety Guide: Dispersion of Radioactive Material in Air and Water and Consideration of Population Distribution in Site Evaluation for Nuclear Power Plants (IAEA 2002b).
Services
The availability and vulnerability of services that are important to safety may influence the assessment of a site. Nearby services and transport routes may contribute to selecting the facility design and an understanding of the impact of a controlled facility on the population and the environment, and the feasibility of offsite emergency intervention.
Services of particular interest include:
electricity, gas, and water supplies, including back-up facilities;
provision of sewerage (which may be relevant to radioactive discharges);
communications;
transportation (road, rail, ship, air);
emergency services (fire, police, ambulance);
presence of facilities containing hazardous materials (e.g. chemical stores, munitions stores) or other hazardous facilities (e.g. chemical plant, fuel depot, power station) either on- or off-site; and
other nearby (collocated) on- or off-site facilities which may also require local services (interdependencies) and could contribute to or be impacted by emergency situations, particularly facilities and services which could potentially increase the risk to the public or the environment in emergency situations.
Radiological Baseline
Before any work commences on a proposed controlled facility, it is important to establish the radiological baseline of the site and surrounding areas, including information on the ambient radioactivity of the natural environment. This information should be used during operation of the facility to monitor performance of those site and facility features that help to isolate the facility from the surrounding environment. The information should also be used at the decommissioning and closure stages of the facility to assist in rehabilitation of the site to (approximately) its original state. Most of the (predictive) models used for assessment of post-closure impacts (including the effectiveness of decommissioning activities) on public health and the environment require a knowledge of the relevant source terms for possible releases of contaminated material to the environment and do not require information about the ambient background.
5.3.2 Events
The short-term events that may occur at a site that could affect the radiological impact of the proposed facility include:
severe weather phenomena such as thunderstorms, lightning, turbulence, cyclones, hail, storm surges, waterspouts, bushfires, drought and dust and sand storms;
floods on sites along streams, rivers and lakes caused by drainage, dam failure, ground water waves, or blockages and diversions in river systems ;
flooding resulting from extreme precipitation events, including those combined with snow and hail if appropriate;
tsunamis and related deposition, erosion and flooding;
seiches, storm surges and tidal variations for coastal regions;
earthquakes, fault displacement and other seismic events;
fires
inadvertent intrusion.
Information should be provided about historical occurrences, the likely future occurrences and potential impacts of these events.
Additional guidance can be found in the IAEA documents: Meteorological and Hydrological Hazards in Site Evaluation for Nuclear Installations (IAEA 2011b); Geotechnical Aspects of Site Evaluation and Foundations for Nuclear Power Plants (IAEA 2004); and Seismic Hazards in Site Evaluation for Nuclear Installations (IAEA 2010b).
5.3.3 Transfer Processes
In order to assess the impact of releases of radionuclides to the environment the on-going processes that can transfer radionuclides to (and through) the environment need to be understood. These processes can be both generic and site-specific.
In normal operating conditions, contaminated material from a facility can enter the environment as a result of processes such as erosion, or via discharge to the atmosphere, discharge to lakes and rivers, surface runoff following ingress of water, degradation of structures and containment barriers, leaching of contaminated material deposited on the ground, and via transport on vehicles and personnel leaving the site. These processes should also be considered when assessing the impact of unplanned releases of radioactive material to the environment.
Transport in the atmosphere
Detailed simulation of atmospheric transport processes requires information on wind direction, wind speed, atmospheric stability, diffusion, and wet and dry deposition. In addition, information considered should also include:
properties of the radioactive material released including total activity, chemical characteristics and physical properties
the type of release, including rate of release, time period of release, geometry and mechanics of discharge (and variation of these factors for different radionuclides).
In most situations the emphasis is on compliance, which means that the criteria against which an impact assessment is carried out are the annual dose limits set out in legislation, regulations or licence conditions. Information previously discussed on geomorphological and demographic features may also be required to complete these assessments.
Note that any airborne radioactive material that is deposited on the ground or on surface water could result in indirect contamination of surface water and/or groundwater.
More detailed guidance can be found in IAEA Safety Guide: Dispersion of Radioactive Material in Air and Water and Consideration of Population Distribution in Site Evaluation for Nuclear Power Plants (IAEA 2002b)).
Transport in the hydrosphere
The hydrosphere is a major pathway through which radioactive materials can be transported in both routine and emergency situations. This transport can occur via surface water (rivers, lakes, oceans and surface runoff), or in groundwater. Typically, radionuclides are transported rapidly in surface waters, and much more slowly in groundwater.
Surface water may become contaminated via direct contamination/discharge, or indirect contamination such as deposition of airborne contamination.
Radioactive materials may contaminate groundwater either directly or indirectly through either one of, or a combination of:
infiltration of contaminated surface water, resulting in leaching of radionuclides into groundwater
leakage of radioactive liquids to groundwater from a storage tank or reservoir
direct penetration into an aquifer.
The leaching process can be very slow and the time taken for contamination to reach measureable levels in groundwater depends strongly on the depth of the aquifer carrying the groundwater. This means that any impact assessment has to be carried out over an appropriate time period.
In all cases information about the source term for the discharge and the hydrological, physical, chemical and biological properties of the radioactive materials released should be considered in order to assess the impact of the discharge on people and the environment. The specific data necessary to assess these transport processes is different for surface water and for groundwater, and also varies depending on the water source (e.g. lakes, rivers, estuaries, seas and oceans, human made impoundments).
Any assessment of surface water and groundwater transport should also consider the features of the site detailed above, with specific consideration of:
agricultural, residential and recreational land use;
agricultural, residential, commercial and recreational water sources and water use;
land and water bodies supporting wildlife and livestock;
impacts on the food chain; and
detailed demographic information.
More detailed guidance can be found in the IAEA Safety Guide: Dispersion of Radioactive Material in Air and Water and Consideration of Population Distribution in Site Evaluation for Nuclear Power Plants (IAEA 2002b).
The aim of any assessment of the impact of a proposed facility for routine operating conditions is to determine whether the proposed facility will comply with all relevant legislative and regulatory requirements. Where an impact assessment is required in the later stages of the site selection process, information will be required on the conceptual facility design, potential source terms (inventory), environmental transfer pathways and exposure scenarios. These have already been discussed in earlier sections. At the siting stage, detailed site-specific information may not be available, so default data (IAEA, 2010) should be used where necessary.
Examples of impact assessments are given in the reports from the Environmental Modelling for Radiation Safety (EMRAS) programme conducted by the IAEA (IAEA 2008; IAEA 2013b).
5.3.5 Emergency Preparedness
Defence in Depth
Defence in depth is an important component of the internationally accepted approach to optimising safety in the siting and design of controlled facilities. It uses multiple layers of protection in such a way that a loss of safety at any level is compensated by the protection provided by additional layers. Further details can be found in ARPANSA’s Regulatory Assessment Principles (ARPANSA 2001a).
Usually only a conceptual design is available for the proposed controlled facility at the siting stage. Therefore it is not possible to address in detail the potential for ‘beyond design basis’ accidents during consideration of the siting licence application, except to the extent that some elements of siting, such as natural barriers, are of importance.
A new concept in international best practice for enhancing nuclear safety is the consideration of ‘design extension conditions’ in the siting and design of a controlled facility (IAEA 2012b, Requirement 20). Design extension conditions are intended to improve safety by enhancing the controlled facility’s capabilities to withstand, without unacceptable radiological consequences, accidents that are either more severe than design basis accidents or that involve additional failures. The main objective in considering design extension conditions at the siting stage is to provide assurance that the site will not compromise the provision of defence in depth.
While design extension conditions are primarily addressed in the design phase of the controlled facility, some considerations during the siting licence application phase could include:
combinations of events and failures, where the results of engineering judgement, deterministic safety assessments and probabilistic safety assessments indicate that combinations of events could lead to accident conditions
physical separation and operational independence of safety systems
optimising avoidance of long term off-site contamination
improvement of the layout, particularly with respect to collocated facilities, to facilitate operation in accidental conditions.
Reference Accident
In the context of this document, which covers a wide range of potential sites and facilities, the concept of a reference accident is used to assess the radiological consequences of a hypothetical, short-term release of a very large quantity of contaminated material to the environment around the site being considered, against criteria intended to protect people and the environment. The radiological consequences of the reference accident should be determined using conservative assumptions.
The use of a reference accident allows the radiological suitability of a site for a proposed controlled facility to be assessed at the conceptual planning stage before the detailed design of the facility is known. The purpose of examining a reference accident at the siting phase is to determine whether there are any gross characteristics of the site that would render it unsuitable from a health and safety perspective, whatever levels of defence in depth are likely to be incorporated in the future design of the facility.
Since the actual design of the proposed facility is unknown at the site selection stage, the reference accident should consider only site-dependent factors (where appropriate to the site under consideration) such as:
discharge to the atmosphere under prevailing meteorological conditions
discharge to rivers, lakes and oceans
deposition on the ground surface and subsequent surface run-off and leaching into groundwater
the effect of natural features of the site on the consequences of such a release
the availability of resources for mitigating the consequences of such a release
the demographics and impact on exposed populations
the consequences of the release with respect to current and future land use
the ease of remediating the site and its surroundings once the emergency stage of the accident is over.
As the project proceeds through the respective licensing phases and the design and operational details of the facility are developed the nature of the reference accident may change.
Where a new controlled facility is planned for a site that already has one or more controlled facilities, the existing facilities should be accounted for when determining the radiological consequences of the reference accident. Further guidance regarding the selection of a reference accident and the criteria by which it is assessed can be found in ARPANSA’s Regulatory Assessment Principles (ARPANSA 2001a).
5.3.6 Preparedness for accident recovery
Site-related criteria that are relevant when considering remediation preparedness following any accident, both in terms of the impact on these criteria of any accident at the chosen site and their potential utility in remediation, include:
demographics, particularly the proximity of towns and cities
value of land – cultural and societal importance of land for agriculture, recreational activities and natural resources
social amenities such as schools and hospitals
availability of, and ease of access, to relevant services including water and power supplies and transport infrastructure
availability of and ease of access to technology to monitor and perform environmental remediation
systems of local governance
communal knowledge and acceptance of the controlled facility; means of communication for dissemination of advice amongst stakeholders
availability of natural and man-made structures to store and dispose of accident waste, including landfill sites; and • geographic parameters.
Annexes
A1. Requirements for Protection of Human Health and the Environment
The requirements for ensuring the protection of people (workers and the public) and the environment, now and in the future, from harmful effects of ionizing radiation are found in the national standard Recommendations for Limiting Exposure to Ionizing Radiation (1995) and National Standard for Limiting Occupational Exposure to Ionizing Radiation (republished 2002, which is prescribed in Regulation 48 of the ARPANS Regulations as a condition of licence) (RPS 1, ARPANSA 2002).
Regulation 41 requires that in deciding to issue a facility licence, the CEO must take into account, amongst other things, whether:
the information establishes that the proposed conduct can be carried out without undue risk to the health and safety of people, and to the environment
the applicant has shown that the magnitude of individual doses, the number of people exposed, and the likelihood that exposure will happen, are as low as reasonably achievable, having regard to economic and social factors.
A1.1 Radiation Protection Principles
The international framework for radiation protection rests on 3 principles, which have been confirmed in the most recent Recommendations of the ICRP in Publication 103 (ICRP 2007). These are justification, optimisation and dose limitation. All of these principles, fundamental to the system for control of exposure to radiation, must be met in accordance with the national standard (ARPANSA 2002). The international framework is continuously evolving and the national framework is continuously revised on that basis, as necessary and appropriate. Note that RPS 1 (ARPANSA 2002) is currently being revised to take into account ICRP Publication 103 (ICRP 2007) and IAEA GSR Part 3 (IAEA 2014b).
A1.1.1 Justification
Justification involves a demonstration that there is a net benefit from a practice which leads to exposure to radiation. As the benefits and detriments to be considered encompass all aspects of the proposed practice, the decision-making process covers far more than radiation protection alone and shall involve all appropriate governmental and societal decision-making agencies. Further details of this principle and guidance in meeting it are found in RPS 1 (ARPANSA 2002).
A1.1.2 Optimisation
Optimisation is employed to make the best use of resources in reducing radiation risks, once a practice has been justified. The broad aim is to ensure that the magnitude of individual doses, the number of people exposed, and the likelihood that potential exposures will actually occur shall all be kept as low as reasonably achievable, economic and social factors being taken into account (ALARA). Further details of this principle and guidance in meeting it are found in ARPANSA 2002 (Recommendations for Limiting Exposure to Ionizing Radiation (1995) and National Standard for Limiting Occupational Exposure to Ionizing Radiation (2002)) and in the ICRP Publication 101b (ICRP 2006b).
A1.1.3 Dose Limitation
Dose Limitation involves applying dose limits and constraints to optimise the total dose to any individual in planned exposure situations. Further details of this principle and guidance in meeting it are found in the following section regarding dose limits and dose constraints and in RPS 1 (ARPANSA 2002).
A1.2 Radiation Protection Criteria
A1.2.1 Public and Occupational Dose Limits and Dose Constraints
In siting and designing a facility, it must be taken into account that during the operational phase, the applicant must show that the design and operation of the facility provides for the protection of workers and members of the public such that:
radiation doses to the public and workers do not exceed the dose limits in Regulations 59 and 60 of the ARPANS Regulations;
facilities are designed and operated in such a way that radiation protection of workers and members of the public is optimised according to the principles described in Regulation 58 of the ARPANS Regulations
the consequences of any reasonably foreseeable fault or accident condition are such that radiation protection of workers and the public is optimised according to the principles described in Regulation 58 of the ARPANS Regulations.
During the operational phase the applicant must also propose a dose constraint for workers, below which protection will be optimised, in accordance with RPS 1 (ARPANSA 2002) and which is agreed to by the CEO. The expectation of the CEO is that the constraint would not exceed 5 mSv per annum.
A2. Definitions
Terms defined in the ARPANS Act and the ARPANS Regulations have the same meaning when the terms are used in this Regulatory Guide. All other definitions in this Guide are intended to be consistent with the definitions in the IAEA Safety Glossary (IAEA 2007).
Community
In this Regulatory Guide the term ‘community’ is used to define the level of spatial and social organisation at which the issue of demographics should be addressed by the license applicant in terms of ‘the impact of the facility on the community in which the facility is, or is to be situated’.
Defence in depth
‘Defence in depth’ is the application of more than one protective measure for a given safety objective, such that the objective is achieved even if one of the protective measures fails. This is often achieved through a hierarchical deployment of different levels of equipment and procedures.
The International Nuclear Safety Group (INSAG) defines five levels of defence in depth:
Level 1: Prevention of abnormal operation and failures.
Level 2: Control of abnormal operation and detection of failures.
Level 3: Control of accidents within the design basis.
Level 4: Control of severe plant conditions, including prevention of accident progression and mitigation of the consequences of severe accidents.
Level 5: Mitigation of radiological consequences of significant releases of radioactive material.
Design basis
The ‘design basis’ is the range of conditions and events that are explicitly taken into account in the design of a facility, such that the facility can withstand them without exceeding authorised limits by the planned operation of safety systems.
Design basis accident
An accident involving conditions that the facility has been designed to withstand while keeping damage to nuclear fuel and the release of radioactive material within authorised limits.
Beyond design basis accident
An accident involving conditions more severe than a design basis accident.
Design extension conditions
A set of conditions derived on the basis of engineering judgement, deterministic assessments and probabilistic assessments for the purpose of further improving the safety of the controlled facility by enhancing the facility’s capabilities to withstand, without unacceptable radiological consequences, accidents that are either more severe than design basis accidents or that involve additional failures. These design extension conditions shall be used to identify the additional accident scenarios to be addressed in the siting and design and to plan practicable provisions for the prevention of such accidents or mitigation of their consequences if they do occur.
Ecosystem
A complex and dynamic community of living (e.g. plants, animals, micro-organisms) and nonliving (e.g. water, air) components that interact as a functional unit.
Graded Approach
An application of safety requirements that is commensurate with the characteristics of the practice or source and with the magnitude and likelihood of the exposures.
Natural Environment
A collective term for all of the physical, chemical, and biological conditions within which wild plants and animals normally live (based on the Environment Protection and Biodiversity Conservation (EPBC) Act).
Nuclear Material
Plutonium except that with isotopic concentration exceeding 80% in plutonium-238; uranium233; uranium enriched in the isotope 235 or 233; uranium containing the mixture of isotopes as occurring in nature other than in the form of ore or ore residue; depleted uranium; thorium; any material containing one or more of the foregoing (IAEA Safety Glossary, IAEA 2007).
For the purposes of safeguards, the Commonwealth Nuclear Non-Proliferation (Safeguards) Act 1987 (Cwth 1987) defines nuclear material in accordance with the Australia-IAEA Comprehensive Safeguards Agreement.
The IAEA places safeguards on nuclear material, which is defined via Article XX of the IAEA Statue and the IAEA document INFCIRC/153 (1972):
"Nuclear material" means any source material or any special fissionable material as defined in Article XX of the Statute. The term source material shall not be interpreted as applying to ore or ore residue.
There are some exceptions as to what nuclear material is covered by this definition, and is therefore controlled under the Nuclear Non-Proliferation (Safeguards) Act 1987, but essentially this means uranium, thorium and plutonium in any quantity or form.
(Nuclear) Security
Security involves the prevention and detection of, and response to, theft, sabotage, unauthorised access, illegal transfer or other malicious acts involving nuclear material, other radioactive substances or their associated facilities.
Radioactive Material
For the purposes of this regulatory guide, radioactive material is material designated in national law or by a regulatory body as being subject to regulatory control because of its radioactivity.
Safety Analysis Report
The safety analysis report is an ARPANSA regulatory requirement that documents the formal safety analysis. In the context of this Regulatory Guide, the safety analysis report, together with the safety assessment, are considered to be appropriate elements of the safety case that demonstrates the safety of the storage or disposal facility. The extent and rigour of the safety analysis report is commensurate with the hazard categorisation of the facility. It is a living document that is updated as appropriate throughout the life of the facility (including the decommissioning stage) to reflect its current state.
Safety Assessment
Assessment of all aspects of a practice that are relevant to protection and safety; for an authorised facility, this includes siting, design and operation of the facility. This will normally include formalised risk assessment.
Safety Case
The ‘safety case’ is a collection of arguments and evidence in support of the safety of a facility or activity. This will normally include the findings of a safety assessment and a statement of confidence in these findings together with the safety analysis report that is an ARPANSA regulatory requirement.
The safety case may relate to a given stage of development (e.g. siting). In such cases, the safety case should acknowledge the existence of any unresolved issues and should provide guidance for work to resolve these issues in future development stages.
Stakeholder
Stakeholder means an interested party — whether a person or a group, etc. — with an interest or concern in ensuring the success of a venture. To ‘have a stake in’ something, figuratively, means to have something to gain or lose by, or to have an interest in, the turn of events. In this Regulatory Guide, the term does not include the major players in the licensing process (proponent, operator, regulator) but does include other national and regional governments and agencies.
Wildlife
‘Wildlife’ is defined as an animal or plant living within its natural environment.
References
All websites accessed on 11 August 2014.
ARPANSA 1999. Criteria for the Siting of Controlled Facilities (draft ARPANSA Regulatory Guideline RG-4).
ARPANSA 2001b. Regulatory Assessment Criteria for the Design of New Controlled Facilities and Modifications to Existing Facilities (Regulatory Guideline RG-5, RB-STD-43-00 Rev 1, October 2001). Available from: http://www.arpansa.gov.au/Regulation/guides#13a
ARPANSA 2002. Recommendations for Limiting Exposure to Ionizing Radiation (1995) and National Standard for Limiting Occupational Exposure to Ionizing Radiation (2002). Radiation Protection Series No. 1 (RPS 1, currently under review).
ARPANSA 2004. Intervention in Emergency Situations Involving Radiation Exposure. Radiation Protection Series No. 7 (RPS 7).
ARPANSA 2007. Code of Practice: Security of Radioactive Sources. Radiation Protection Series No. 11 (RPS 11).
ARPANSA 2008. Code of Practice: Safe Transport of Radioactive Material. Radiation Protection Series No.2 (RPS 2).
ARPANSA 2011. National Directory for Radiation Protection. Radiation Protection Series No. 6.
ARPANSA 2012b. Regulatory Guide: Applying for a Facility Licence for a Nuclear Installation v5 (OS-LA-SUP-240G, August 2012). Available from: http://www.arpansa.gov.au/Regulation/guides#2
ARPANSA 2012c. Regulatory Guide: Applying for a Facility Licence for a Prescribed Radiation Facility v5 (OS-LA-SUP-240F, August 2012). Available from: http://www.arpansa.gov.au/Regulation/guides#2
ARPANSA 2013a. Regulatory Guide: Licensing of Radioactive Waste Storage and Disposal Facilities v2 (OS-LA-SUP-240L, March 2013).
IAEA 2002a. External Human Induced Events in Site Evaluation for Nuclear Power Plants (IAEA Safety Standards Series, Safety Guide No. NS-G-3.1).
IAEA 2002b. Dispersion of Radioactive Material in Air and Water and Consideration of Population Distribution in Site Evaluation for Nuclear Power Plants (IAEA Safety Standards Series, Safety Guide No. NS-G-3.2).
IAEA 2003. Site Evaluation for Nuclear Installations (IAEA Safety Standards Series, Safety Requirements No. NS-R-3).
IAEA 2004. Geotechnical Aspects of Site Evaluation and Foundations for Nuclear Power Plants (IAEA Safety Standards Series, Safety Guide No. NS-G-3.6).
IAEA 2007. IAEA Safety Glossary: Terminology Used in Nuclear Safety and Radiation Protection. 2007 Edition.
IAEA 2008. Modelling the Transfer of Radionuclides from Naturally Occurring Radioactive Material (NORM) in Environmental Modelling for Radiation Safety (EMRAS) – A Summary Report of the Results of the EMRAS Programme (2003-2007). Available from: http://www-pub.iaea.org/MTCD/Publications/PDF/TE_1678_Web.pdf
IAEA 2009. Safety Assessment for Facilities and Activities (IAEA Safety Standards Series, General Safety Requirements No. GSR Part 4).
IAEA 2010a. Governmental, Legal and Regulatory Framework for Safety (IAEA Safety Standards Series, General Safety Requirements No. GSR Part 1).
IAEA 2010b. Seismic Hazards in Site Evaluation for Nuclear Installations (IAEA Safety Standards Series, Specific Safety Guide No. SSG-9).
IAEA 2011a. Nuclear Security Recommendations on Physical Protection of Nuclear Material and Nuclear Facilities (IAEA Nuclear Security Series No. 13, INFCIRC/225/Revision 5).
IAEA 2011b. Meteorological and Hydrological Hazards in Site Evaluation for Nuclear Installations (IAEA Safety Standards Series, Specific Safety Guide No. SSG-18). IAEA 2012a. Volcanic Hazards in Site Evaluation for Nuclear Installations (IAEA Safety Standards Series, Specific Safety Guide No. SSG-21).
IAEA 2012b. Safety of Nuclear Power Plants: Design (IAEA Safety Standards Series, Specific Safety Requirements No. SSR-2/1). IAEA 2013a. Site Survey and Site Selection for Nuclear Installations (IAEA Safety Standards Series, draft Safety Guide No. DS433, endorsed for publication, CSS Nov 2013).
IAEA 2014a. Decommissioning of Facilities (IAEA Safety Standards Series, General Safety Requirements No. GSR Part 6).
IAEA 2014b. Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards (IAEA Safety Standards Series, General Safety Requirements No. GSR Part 3).
IAEA 2014c. Radiation Protection of the Public and the Environment (IAEA Safety Standards Series, draft Safety Guide No. DS432).
IAEA 2014d. A General Framework for Radiological Environmental Impact Assessment and Protection of the Public (IAEA Safety Standards Series, draft Safety Guide No. DS427).
ICRP 2006a. Assessing Dose of the Representative Person for the Purpose of the Radiation Protection of the Public (ICRP Publication 101a, Ann. ICRP 36 (3)).
ICRP 2006b. The Optimisation of Radiological Protection - Broadening the Process (ICRP Publication 101b, Ann. ICRP 36 (3)).
ICRP 2007. The 2007 Recommendations of the International Commission on Radiological Protection (ICRP Publication 103, Ann. ICRP 37 (2-4)). Larsson 2013. Chairperson’s Summary, International Experts Meeting on Decommissioning and Remediation after a Nuclear Accident (C-M. Larsson, IAEA IEM4, 28 Jan – 1 Feb 2013).
NHMRC 1985. Code of Practice for the Disposal of Radioactive Wastes by the User (Radiation Health Series No. 13).
NHMRC 1992. Code of Practice for the Near-Surface Disposal of Radioactive Waste in Australia (Radiation Health Series No. 35).
ARPANSA’s expectations for how a licence holder or applicant will manage the safety and security of facilities and sources
Introduction
This guide sets out ARPANSA’s expectations for how a licence holder or applicant will manage the safety and security of facilities and sources.
Under the Australian Radiation Protection and Nuclear Safety Act 1998 (the Act) and Australian Radiation Protection and Nuclear Safety Regulations 2018 (the Regulations), licence holders must develop and follow their own plans and arrangements to manage safety. This requirement is consistent with Principle 1 of the International Atomic Energy Agency’s Fundamental Safety Principles SF-1 which states that ‘the prime responsibility for safety is with the person or organisation responsible for facilities and activities that give rise to radiation risks.’
Sections 46 and 47 of the Regulations set out the information that is required in a licence application; this includes plans and arrangements that describe how the applicant proposes to manage the safety of the facility or source. Further information that the CEO may request will vary depending on the type of application but may also include siting, design or construction plans, operating limits and conditions, preliminary or final safety analysis report, source identification and location details, etc.
The CEO must be satisfied that the information provided demonstrates that the proposed conduct (for a facility) or proposed dealing (for a source) can be carried out without undue risk to
the health and safety of people and the environment. For facilities, this information will be collated in a safety case. The safety case is the collection of scientific, technical, administrative and managerial arguments and evidence in support of the safety of a facility, covering the suitability of the site and the design, construction and operation; the assessment of radiation risks and assurance of the adequacy and quality of all of the safety related work that is associated with the facility.
A major component of the safety case is the safety assessment, which includes the safety analysis. Important elements of the safety assessment are radiological impact on humans and the environment, site and engineering aspects, operational safety, non-radiological impacts and the management system. The safety analysis is the evaluation of the potential hazards associated with a facility or activity, documented in a safety analysis report (SAR). The safety case with its supporting safety assessment provides the basis for demonstrating safety for licensing purposes.
The arrangements in place to establish and manage a facility or activity, and the interdependencies between such arrangements, should be documented in a management system. A management system designed to support the object of the Act will integrate safety, health, environmental, security, quality, societal and economic elements.
The management system should foster and promote a culture for safety and security, which takes into account human factors such as attitudes and behaviour, as well as the general mindset by which all workers, including senior management, approach safety. These factors should interact with the technological and organisational factors in a way that promotes holistic safety (often referred to as systems safety), which is considered a best practice approach to safety management. A holistic approach to safety ensures the technology is safe to use; people perform tasks safely at work; and the organisation overall is managed safely.
Once a licence is issued and an applicant becomes a licence holder, section 60 of the Regulations requires the licence holder to comply with their plans and arrangements. Changes to plans and arrangements that will have significant implications for safety can only be made after the licence holder has sought and obtained approval from the CEO of ARPANSA under section 63 of the Regulations. Changes unlikely to have significant implications for safety do not need prior approval but must be reported to the CEO within three months under section 64 of the Regulations. Under section 61 of the Regulations, the licence holder must, at least every three years, review their plans and arrangements and keep and maintain records of the review and any changes.
Scope and Purpose
This Guide is applicable to both sources and facilities. Its purpose is to outline those key aspects that should comprise an organisation’s plans and arrangements for managing safety. It should be applied to the extent practicable and commensurate with the degree of hazard associated with the conduct or dealing. For example, the plans and arrangements for a complex facility will be different to those for a low hazard source. A graded approach is important to ensure that efforts and resources are directed to the matters that are most significant for protection of health and safety of people and the environment.
This Guide may be useful to applicants or licence holders to draft, modify or review some or all of their plans and arrangements.
ARPANSA will take this Guide into consideration when:
assessing an applicant’s plans and arrangements when submitted as part of a licence application.
assessing and monitoring licence holders’ compliance with the requirement to update any plans and arrangements for managing controlled facilities, controlled material or controlled apparatus under section 61 of the Regulations.
assessing requests for approval to make a change with significant implications for safety under section 63 of the Regulations.
overseeing general compliance through inspections, site visits, meetings, etc.
ARPANSA has drawn on international best practice to prepare this Guide. Where appropriate, links to trusted international standards and additional guidance are provided; applicants are expected to take these into account when developing and reviewing their plans and arrangements.
Structure
This Guide has eight chapters, based on sections 46 & 47 of the Regulations. Links to additional ARPANSA guidance and international standards are provided at the end of each chapter.
Statutory and regulatory compliance underpin all operations.
Plans and arrangements should demonstrate:
1.1 The processes or systems that will allow all relevant and applicable statutory and regulatory requirements to be identified.
1.2 How important statutory and regulatory compliance aspects will be shared and communicated to relevant personnel.
1.3 How all operations and functions will be in compliance with the identified requirements.
1.4 How the licence holder will ensure it stays up-to-date with applicable regulatory requirements.
Management commitment
Management is committed to maintaining safe and secure operations and work environment.
Plans and arrangements should demonstrate:
1.5 Management’s support, promotion and endorsement of the plans and arrangements and their use throughout the organisation1.
1.6 Management’s commitment to:
ensuring compliance with statutory and regulatory obligations
allocating adequate resources to safety and security
maintaining control over the source or facility
1.7 Management’s commitment to the principles of holistic safety:
human aspects and human performance
organisational aspects including safety culture and organisational learning
technological aspects
interactions between technical, human and organisational factors in the management of safety
1.8 How management’s commitment to the aforementioned will be clearly understood by all staff and promulgated across the organisation.
Accountabilities and responsibilities
Accountabilities and responsibilities are identified for all key functions and operations.
Plans and arrangements should demonstrate:
1.9 Accountabilities and responsibilities, including delegations, are clearly defined and described for:
the overall management of the plans and arrangements are clearly defined2
all conducts, dealings and operations and maintaining control over the source or facility
safety and security
statutory and regulatory compliance
resources
process implementation
1.10 Accountabilities and responsibilities are mapped out clearly for each section, branch and division.3
1.11 Systems are in place to ensure staff are fully aware of their own accountabilities and responsibilities and also those of other staff.
Resources
Resources are adequately allocated and controlled.
Plans and arrangements should demonstrate:
1.12 The systems in place to identify resource requirements.
1.13 How the organisation’s resources will be controlled.
1.14 How radiation protection and nuclear safety will be considered in allocation of resources.
1.15 The systems used to track and monitor resources.
1.16 The systems used to review resource allocations if circumstances change to ensure continued safety and security of operations.
Communication
Information is effectively communicated throughout the organisation.
Plans and arrangements should demonstrate:
1.17 Communication needs and requirements have been identified.
1.18 How communication processes and infrastructure will be maintained or put in place to address this need.
1.19 What modes of communication all staff, including contractors, are expected to use4.
1.20 How all staff, including contractors, is able to communicate information with radiation protection and nuclear safety implications efficiently and effectively.
Process implementation
Operations, processes, functions and activities are adequately controlled.
Plans and arrangements should demonstrate:
1.21 There is a consistent method or approach to develop, approve and roll-out new processes and operations, or review existing ones.
1.22 The systems that will be used to encourage all staff, including contractors, to follow and adopt this method or approach.
1.23 How staff and stakeholder consultation will be included or involved in process development and implementation.
1.24 How process implementation will be monitored and controlled.
Documentation and document control
Documentation is organised and effectively managed.
Plans and arrangements should demonstrate:
1.25 All processes, both administrative and practical, with implications for safety or security, is carried out in accordance with written procedures.
1.26 All conducts, dealings and operations with implications for radiation protection and nuclear safety are adequately documented and periodically reviewed.
1.27 There are criteria, methods or manuals outlining what specific processes and operations need to be documented5.
1.28 There are systems in place to ensure documents are integrated and consistent with one another6.
1.29 The systems used to ensure documents are quickly and easily accessible staff (including contractors) who need them.
1.30 Documents are managed in an appropriate quality system (preferably accredited).
Footnotes to Chapter 1
1 For example, this could be demonstrated by the CEO signing them.
2 For example, this should be someone who has ultimate responsibility for the plans and arrangements.
3 For example, this could be an organisational chart showing the organisational structure.
4 It should be noted that these modes may vary depending on safety and security needs.
5 For example, which operations require procedures, instructions, workflows, SOPs.
6 For example, methods clearly link to overarching organisational policies (vertically) and methods which describe operations integrate with one another (horizontally). Having a method, proforma or ‘document manual’ would help with this process, as is commonly applied by other organisations.
Overarching policies and objectives for safety are clearly defined.
Plans and arrangements should demonstrate:
2.1 An adequate overarching safety policy exists related to all functions, operations, conducts and dealings.
2.2 Safety objectives are clearly outlined7.
2.3 How all staff will be encouraged to fully adopt the safety policy and objectives and how the CEO (or management equivalent) will endorse their use.
2.4 The systems to ensure the safety policy and objectives will be communicated and understood by all staff8.
2.5 The systems to ensure the policy will be monitored, reviewed and kept up-to-date.
Monitoring and Measurement
Operations are tracked, monitored and measured.
Plans and arrangements should demonstrate:
2.6 Processes used to collect safety data, including from incidents, accidents, exceedances, events, tests, walk-downs, assessments, observations, reports, audits, comments and suggestions.
2.7 Processes in place to observe, assess and promote a good safety culture.
2.8 The systems, processes or infrastructure that is used to report and communicate safety data.
2.9 What type of safety data that will be collected i.e. reactive and predictive data.
2.10 Clear systems or processes used to encourage reporting and communication of data.
2.11 How this data and other safety related data will be securely collected, stored and analysed (see Risk Assessment and Mitigation below regarding analysis of data).
2.12 How differences between how things are done versus how they are described will be identified9.
2.13 How hazards throughout all operations, conducts and dealings will be identified.
Risk assessment and mitigation
Risks are reduced to acceptable levels by applying risk assessment and mitigation strategies.
Plans and arrangements should demonstrate:
2.14 The process by which safety and security data collected from monitoring and measurement is assessed.
2.15 This assessment process enables safety and security data to be filtered and assessed according to the risk.
2.16 The systems to ensure staff designated to conduct this risk assessment have appropriate experience, knowledge and competence.
2.17 There is a threshold or criteria that determine when deviations from an expected outcome are investigated.
2.18 How investigations will take place and how they will be conducted. This should include investigations of breaches required under section 57 of the Regulations.
2.19 Methods are clearly outlined for conducting investigations and how personnel with sufficient knowledge, experience and competence will be involved.
2.20 Processes are in place to develop control measures for risks that warrant mitigation.
2.21 Implementation of risk mitigation measures according to change control and process implementation guidelines and procedures (see 'Managing Change' below and also Process Implementation under Effective Control).
Managing change
Changes are safely managed.
Plans and arrangements should demonstrate:
2.22 A formal change management policy and process is in place.
2.23 How the need and objective for change will be identified or established.
2.24 The systems or processes used to develop options to meet this change objective.
2.25 How each option’s safety benefits, detriments and risks will be evaluated and compared.
2.26 How the preferred option(s) will be identified.
2.27 How plans to effectively implement the preferred option(s) are developed and how these plans are consistent with process implementation guidelines or instructions.
2.28 The systems or processes to ensure that the implemented change will be controlled and monitored so that safety is maintained and not degraded.
2.29 How the whole change process will be reviewed to ensure the change has been effective in meeting its radiation protection and nuclear safety objectives.
Learning and continuous improvement
Learning from experience and continuous improvement underpin all operations.
Plans and arrangements should demonstrate:
2.30 A policy or procedures are in place to ensure learning and continuous improvement occurs for all operations (including security and emergency preparedness and response).
2.31 The systems, processes or performance criteria used to determine when operations or functions are reviewed for the purpose of learning and continuous improvement.
2.32 How the review will take place and who will be involved.
2.33 The systems or processes that will allow the learning processes to be identified and shared across the organisation, where applicable10.
2.34 How improvements identified through the above processes will be implemented in a controlled manner.
2.35 How audit processes will be in place to ensure these improvement are actually being implemented on the shop floor, resulting in continuous improvement.
Training and education
Staff are provided with appropriate safety training and education programs.
Plans and arrangements should demonstrate:
2.36 The systems or processes used to identify and determine the competency requirements for operations with safety implications.
2.37 How safety training needs for staff (and their respective role and job functions) will be identified to maintain and meet these competency requirements. Training programs should be informed by performance assessment and should be periodically reviewed for effectiveness.
2.38 An adequate plan, program or method exists to ensure these training requirements continue to be met, such as succession-planning or refresher training.
2.39 There is a systematic process for developing, approving and reviewing training to ensure it is effective and continues to meet operational needs.
2.40 The systems or processes used ensure the content and delivery of the training involves stakeholder consultation, takes into account adult learning styles and other relevant factors so that the training is effective.
2.41 How training records for all staff will be controlled, monitored and kept up-to-date.
Footnotes to Chapter 2
7 These are the aims the organisation has with respect to safety.
8 An example could be that this is prominently displayed to staff.
9 This is equivalent to work as done versus work as imagined. It is important to evaluate this because it helps identify drift in operations i.e. both local and organisational operations and functions.
10 For example, this could include learning from deviations or any other functioning which the organisation can learn from for the purpose of improving operational safety and security.
The fundamental principles of optimisation, justification, limitation are taken into account.
Plans and arrangements should demonstrate:
3.1 Conducts and dealings are justified, that is, they must produce a net benefit to the exposed individual or the community, taking into account social, economic and other relevant factors.
3.2 The normal exposure of individuals must be limited so that neither the total effective dose nor the total equivalent dose to relevant organs or tissues, caused by the possible combination of exposures from conducts and dealings, exceeds any relevant dose limit specified in the Regulations.
3.3 For any conduct or dealing under the licence holder or applicant’s control, protection and safety must be optimised so that the magnitude of individual doses, the number of people exposed and the likelihood of incurring exposures are kept as low as reasonably achievable (ALARA), taking into account economic and social factors. For each radiation source, the level of radiation protection provided is optimised so that both individual and collective (normal and potential) exposures are kept ALARA.
3.4 The optimisation of the protection and safety measures associated with any particular conduct or dealing must be subject to dose constraints, the value of which is agreed by ARPANSA. Selection of dose constraints should be based on international best practice.
3.5 Provisions for appropriate reference levels11 above which some specific actions or decisions are taken. The reference levels may include recording levels, investigation levels, action levels, and intervention levels (see also Section 7: Emergency).
3.6 The consideration of wildlife (plants and animals) in their natural habitats. Protection should be subject to a screening dose rate for wildlife of 10 µGy/h for a conservative assessment. If this is exceeded, species-specific optimisation is required based on observed effects data in the form of Environmental Reference Levels (see Section 8: Environment Protection Plan).
3.7 Exposure to non-ionising radiation is kept below relevant exposure limits and to the lowest level that can be achieved, consistent with best practice.
Radiation safety officer
A suitably qualified radiation safety officer (RSO) is appointed as appropriate, to undertake specific duties in relation to radiation protection and nuclear safety.
Plans and arrangements should demonstrate:
3.8 A RSO has been appointed if:
The annual doses have the potential to exceed 10% of the limits prescribed in the Regulations
The conduct involves a controlled facility
The dealing involves Group 2, Group 3 or hazardous non-ionising radiation sources (eg Class 4 lasers)
3.9 The RSO has operational duties that are clearly specified in the radiation protection plan.
3.10 The RSO has sufficient knowledge of the Act and Regulations, relevant codes of practice, such as the ARPANSA Radiation Protection Series, Radiation Health Series, relevant Australian Standards and other guidance material and information relevant to the duties of the RSO, to facilitate the achievement of best practice for the conduct or dealing being undertaken.
Radiation safety committee
A suitably qualified radiation safety committee (RSC) is appointed as appropriate, to undertake specific duties in relation to radiation protection and nuclear safety.
Plans and arrangements should demonstrate:
3.11 A RSC has been established if any of the following are met:
The conduct or dealing has multiple activities involving controlled facilities, controlled apparatus and controlled material, or is spread over a number of premises.
The annual doses of ionising radiation from any conduct or dealing at any of the premises has the potential to exceed 10% of the limits specified in the Regulations.
There is potential exposure to non-ionising radiation above the limits specified in Schedule 1 of the Regulations.
3.12 The RSC has functions that are clearly specified in the radiation protection plan.
3.13 The RSC acts as an administrative and consultative body that reviews the radiation protection plans and policies for all conducts and dealings within the organisation and recommends to the licence holder or applicant the radiation protection policy that should be implemented.
3.14 The RSC is of size and membership determined by the type and size of the organisation using controlled facilities, controlled apparatus and controlled material.
3.15 The RSC meets at regular intervals (eg. quarterly) and hold special meetings to review important safety issues as required.
3.16 The RSC deputises persons for the Chair, the Secretary/Executive Officer and the RSO if any of them is unable to attend a meeting.
3.17 The RSC has standing orders relating to a quorum of members which would normally consist of at least one half of the committee membership including the Chair (or their deputy) and the RSO (or their deputy).
3.18 The RSC has a standard agenda item for the RSO to present a report on the state of radiation protection in the organisation.
3.19 The RSC keeps minutes of the RSC meetings that should be ratified at following meetings of the RSC.
3.20 The RSC forwards a copy of the RSC minutes to the senior management of the organisation.
3.21 The RSC establishes and maintains a channel of communication with the work health and safety committee of the organisation (if one exists).
3.22 The RSC undertakes consultation with controlled person and visitors who may be exposed to radiation in their work, and with controlled persons’ representatives, where appropriate.
Planning and design of the workplace
Design of the workplace is optimised for radiation protection consistent with international best practice12
Plans and arrangements should demonstrate:
3.23 The planning, design and construction of the workplace where conducts and dealings are undertaken is in compliance with trusted international standards.
3.24 The workplace has been planned and designed to ensure that:
Doses, including effective dose and equivalent dose, are in compliance with prescribed dose limits and are as low as reasonably achievable (ALARA), economic and social factors being taken into account, and that appropriate dose constraints have been used.
For each radiation source, the level of radiation protection provided is optimised so that both individual and collective (normal and potential) exposures are kept ALARA.
Exposure to ionising radiation is in compliance with a source related dose constraint of 10% of the effective dose limits specified in the Regulations (or another percentage agreed with the CEO).
Exposure to non-ionising radiation is kept below relevant exposure limits to the lowest level that can be achieved.
3.25 Priority is given to engineering controls (including ventilation, interlocks and shielding) to minimise reliance on administrative controls and personal protective equipment.
Classification of work areas
Work areas are classified in accordance with ARPANS legislation and trusted international standards.
Plans and arrangements should demonstrate:
3.26 Areas are classified as controlled areas wherever:
There exists a potential for significant internal or external exposure from radiation or contamination.
It is required to control normal exposures or prevent the spread of contamination during normal working conditions.
Measures are required to prevent or limit the extent of potential exposures.
3.27 Controlled areas are delineated by physical means or, where this is not reasonably practicable, by some other suitable means.
3.28 Suitable warning symbols and appropriate instructions are displayed at access points and other appropriate locations within controlled areas.
3.29 Appropriate occupational protection and safety measures are established for each controlled area, including the provision of local rules and procedures.
3.30 The following items are provided, as appropriate, at exits from controlled areas:
equipment for monitoring for contamination of skin and clothing
equipment for monitoring for contamination of any object or substance being removed from the area
washing or showering facilities
suitable storage for contaminated protective clothing and equipment
3.31 Supervised areas should be:
delineated by appropriate means
indicated by approved signs at appropriate access points
reviewed periodically to determine any need for protective measures and safety provisions, or changes to the boundaries
Local rules and procedures
Local rules and procedures are implemented for protection and safety of workers and other persons.
Plans and arrangements should demonstrate:
3.32 Implementation of local rules and procedures that describe:
Person responsible for radiation safety, and emergency arrangements in the event of an accident and/or incident
Accountability of sources
Managing criticality safety as applicable
Decontamination
Calibration and maintenance of equipment
Investigation level or authorised level, and measures to be followed in the event that any such level is exceeded
Personal protective equipment
Adequate and appropriate personal protective equipment is provided.
Plans and arrangements should demonstrate:
3.33 Controlled persons and visitors are provided with adequate and appropriate personal protective equipment which meets relevant standards or specifications, including:
protective clothing
protective respiratory equipment for which the protection characteristics are made known to the user
protective aprons, gloves and organ shields
3.34 Controlled persons and visitors receive adequate instruction in the proper use of respiratory protective equipment, where appropriate, including testing for good fit.
3.35 Tasks requiring the use of some specific personal protective equipment are assigned only to controlled persons who on the basis of medical advice are capable of safely sustaining the extra effort necessary.
3.36 All personal protective equipment is maintained in proper condition and tested at regular intervals.
3.37 Appropriate personal protective equipment is maintained for use in the event of intervention.
Monitoring of the workplace
Regular radiation and contamination monitoring of the workplace is conducted where appropriate.
Plans and arrangements should demonstrate:
3.38 A workplace monitoring program is established, maintained and regularly reviewed under the supervision of a RSO.
3.39 Workplace monitoring includes, as appropriate:
Leak and wipe tests
External ionising radiation levels
Surface contamination levels
Airborne contamination monitoring levels
Readily accessible exposure levels for non-ionising radiation.
3.40 Standard operating procedures are adhered to when workplace monitoring surveys are performed.
3.41 All monitoring instruments are calibrated periodically as required and the calibration of instruments checked prior to use.
3.42 Written reports are prepared following each workplace survey and made available to controlled persons.
3.43 Reports are referred to appropriate persons and any non-routine occurrences are investigated and appropriate action taken.
3.44 How survey results are analysed for risks and trends (See Risk Assessment and Mitigation).
Monitoring of individuals
Individuals monitoring and assessment of exposure to controlled persons and visitors.
Plans and arrangements should demonstrate:
3.45 That there is a clear, evidence-based rationale for the decision whether or not to implement a system of individual monitoring.
3.46 Individual monitoring is undertaken where appropriate and is adequate and feasible for any controlled person who is normally employed in a controlled area, or who occasionally works in a controlled area and may receive significant exposure.
3.47 Where individual monitoring is inappropriate, inadequate or not feasible, the exposure of the controlled person is assessed on the basis of the results of monitoring of the workplace and on information on the locations and duration of exposure of the controlled person. 3.48 The nature, frequency and precision of individual monitoring is determined with consideration of the magnitude and possible fluctuations of exposure levels and the likelihood and magnitude of potential exposures.
3.49 Controlled persons who enter and work in controlled and supervised areas are required to wear appropriate dosimetry devices (eg whole body exposure dosimeters, extremity exposure dosimeters, direct reading dosimeters, personal air samplers).
3.50 Visitors who enter controlled or supervised areas are required to wear a direct reading dosimeter and be accompanied by a controlled person.
3.51 Dosimetry devices are worn in the correct location and manner.
3.52 Controlled persons and visitors who may be exposed to radioactive contamination are identified and appropriately monitored (eg by bioassay and whole body monitoring) to demonstrate the effectiveness of the protection provided and to assess the intake of radioactive substances or the committed doses.
3.53 Equivalent, effective and collective doses received by controlled persons and visitors are assessed and collated.
3.54 Individual and collective doses are monitored and reviewed on a regular basis by the RSO and/or RSC.
3.55 Abnormal dose results are reported and investigated and actions are taken to avoid recurrence.
3.56 Exposures to non-ionising radiation received by controlled persons and visitors are assessed, including the determination of parameters which affect the exposure.
Monitoring of the environment
The licence holder or applicant is responsible for ensuring that plans and arrangements are in place and are implemented for the monitoring of the environment where appropriate.
Plans and arrangements should demonstrate:
3.57 All potential exposure pathways to the natural environment have been identified, including direct effects to wildlife in their natural habitats.
3.58 The level of potential exposure has been assessed for all potential exposure pathways.
3.59 Pathway analysis and relevant calculations are performed for each potential exposure pathway.
3.60 Where ongoing environmental monitoring is not considered necessary for a specific potential exposure pathway, this decision must be justified by appropriate analysis and calculations.
3.61 For those potential exposure pathways where exposure levels could be significant, an ongoing environmental monitoring regime is established, maintained and regularly reviewed.
3.62 The environmental monitoring regime complies with relevant standards and codes and is in accordance with international best practice.
Transport
The licence holder or applicant is responsible for ensuring that arrangements are implemented for the safe transport of controlled apparatus and controlled material, both on and off site, in compliance with the ARPANS legislation and international standards and codes.
Plans and arrangements for off-site transport should demonstrate compliance with the following where appropriate:
NOTE: ARPANSA does not administer the 1ADG Code or DGR however compliance is considered best practice and will be required by state and territory regulators for goods entering or passing through their jurisdictions.
Plans and arrangements for on-site transport should demonstrate:
3.63 The non-fixed contamination on the external surfaces of any package is kept as low as practicable and under the routine conditions of transport not exceeding the following limits averaged over any area of 300 cm2 of any part of the surface:
4 Bq/cm2 for beta and gamma emitters and low toxicity alpha emitters
0.4 Bq/cm2 for all alpha emitters
3.64 Use of a designated vehicle with appropriate labels and placards, as required.
3.65 A radiation safety officer is consulted if the surface dose of a package exceeds 2 mSv/hr to ensure appropriate arrangements are implemented including use of an over pack.
3.66 The integrity of shielding material used in the package design is maintained during on-site transport.
3.67 Any packages that are not certified by the Competent Authority13 use standard engineering design and proven technology.
3.68 Nuclear criticality safety is maintained and health physics coverage is provided for any package used for transport of fissile material.
3.69 Appropriate contamination clearance certification procedures.
3.70 Appropriate response to leakage, breakage, or abnormal occurrence.
3.71 In the case of spent fuel and fissile material, appropriate consideration and analysis of accident conditions.
3.72 Maintenance of all records of on-site transport including non-conformance and abnormal occurrences in an appropriate quality format.
Footnotes to Chapter 3
11 Diagnostic Reference Levels are used in medical imaging. The use of ionising radiation in medicine is covered by RPS C-5 Code for Radiation Protection in MedicalExposure (2019). See also the associated Safety Guides:
12 For controlled facilities applicants or licence holders should refer to other regulatory guides specifically for facilities on the ARPANSA website.
13 The CEO of ARPANSA is the Competent Authority for the transport of radioactive material by a Commonwealth entity and/or controlled person (as defined in section 13 of the Act) by road, rail and inland waterways within Australia.
Additional ARPANSA Fundamentals and Codes relevant to radiation protection:
The licence holder or applicant is responsible for ensuring that all radioactive waste (including gaseous and liquid discharges) arising from conducts and dealings, existing and anticipated, is appropriately managed.
Plans and arrangements should demonstrate:
4.1 A description of the arrangements for the safe handling, treatment, transport, storage and ultimate transfer or disposal of any waste arising from all past, current and proposed conducts and dealings.
4.2 A full description of the physical, chemical and radiological properties of the waste (including gaseous and liquid discharges) arising from all past, current and proposed conducts and dealings.
4.3 Arrangements for the minimisation of radioactive waste generation.
4.4 Processes for the collection, segregation, characterisation, classification, treatment, conditioning, storage and disposal of radioactive waste.
4.5 Provision for the safe handling of waste by having appropriate handling equipment and selecting short and uncomplicated routes.
4.6 An assessment is performed of the integrity of waste control measures to ensure that they are fault tolerant.
4.7 If fissile material is present, documentation (including calculations) to assess whether criticality is possible. If criticality is possible, documentation detailing the provisions for ensuring that criticality cannot occur. (See also Local Rules and Procedures 3.32)
4.8 Compliance with the requirements of appropriate statutory authorities and any local regulations (eg. Trade Waste Agreements).
Limiting exposure to radioactive waste
The licence holder or applicant is responsible for ensuring that exposure levels to radiation workers and members of the public are limited during the handling, treatment, transport, storage and transfer or ultimate disposal of radioactive waste.
Plans and arrangements should demonstrate:
4.9 Identification of all credible exposure pathways for all radioactive waste.
4.10 How exposure is limited during handling, treatment, transport, storage and transfer or ultimate disposal of all radioactive waste.
4.11 Processes for monitoring and assessing results to show that discharges are within specified limits. These procedures must clearly specify the following:
A reference to the method used for deriving the limits for the particular discharge pathway
The method of keeping records to show that these limits are not exceeded
Actions to be taken when radioactive waste discharges approach or exceed the discharge limit.
4.12 Documented system for demonstrating and reporting compliance with discharge limits based on the following:
The monitoring of discharges
Environmental monitoring results
Dose assessments, including independent checking of results and use of conservative methods and modelling.
Packaging and containment of radioactive waste
The licence holder or applicant is responsible for ensuring that radioactive waste arising from all conducts and dealings is packaged and contained to minimise the potential for migration or dispersion of radionuclide and to limit the external dose rate to within acceptable limits.
Plans and arrangements should demonstrate:
4.13 Provision of appropriate waste handling and packaging areas and facilities.
4.14 Documented procedures to ensure that containers are clearly labelled with the radiation warning sign, a description of the radioactive contents (ie. the radionuclide and form of the waste), the activity when packaged, the date of packaging and the name of the person who is to be contacted for further information or in the event of an abnormal occurrence.
4.15 Documented procedures for performing and recording dose rate measurements at the surface of each package and at one metre from the surface of each package to ensure compliance with the maximum allowable dose rates.
4.16 Provision of non-flammable spillage trays (with 2.5 times the volume of waste) for containers of liquid waste.
Storage of radioactive waste
The licence holder or applicant is responsible for ensuring that all radioactive waste arising from existing and anticipated conducts and dealings is stored safely. The licence holder or applicant is also responsible for ensuring that all such stores are adequately sited, designed, constructed, operated, secured and maintained to allow for the optimisation of provision of safe custody of the waste packages, and for the protection of persons, property and the environment from radiological hazards associated with radioactive waste.
Plans and arrangements should demonstrate:
4.17 Arrangements for storage of radioactive waste consider suitable provisions for safety and security including:
Location and adequate storage capacity
Suitability of the package for the type of storage and for the foreseeable time frame of storage
Use of adequate engineering controls (e.g. shielding, ventilation, monitoring equipment) and administrative controls (e.g. local rules and procedures)
Documented procedures for inspection, maintenance and monitoring
Documented procedures for managing criticality safety for waste containing fissile material
Documentation of radioactive waste
The licence holder or applicant is responsible for ensuring that documentation detailing the nature of any radioactive waste arising from conducts and dealings, its location, and all safety and security procedures is maintained.
Plans and arrangements should demonstrate:
4.18 Procedures for ensuring that an accurate inventory is kept of all waste packages and containers and their contents. An adequately maintained register or database should include:
The radionuclide type/content (physical, chemical and radiological characteristics)
The chain of custody (including details of acceptance, movement, storage, discharge and disposal)
The waste matrix used for immobilisation
The treatment or conditioning method
The ID number of the package (ie. a unique package designator).
4.19 Maintenance of documentation detailing any local government, State or Territory approvals and requirements which the licence holder or applicant is obliged to follow.
Routine discharge of radioactive waste to the sewer
The licence holder or applicant is responsible for ensuring that all radioactive waste arising from existing and anticipated conducts and dealings that is to be discharged to the sewer is disposed of safely.
Plans and arrangements should demonstrate:
4.20 Arrangements to ensure that the limits imposed by state or local water authorities are not exceeded. This may include a system for holding liquid waste in tanks to allow decay prior to disposal.
Routine discharge of radioactive waste to the atmosphere
The licence holder or applicant is responsible for ensuring that all radioactive waste arising from existing and anticipated conducts and dealings that is to be discharged to the atmosphere is disposed of safely.
Plans and arrangements should demonstrate:
4.21 A system to ensure that discharge of radioactive waste to the atmosphere does not exceed statutory limits.
The licence holder or applicant is responsible for ensuring that all radioactive waste arising from existing and anticipated conducts and dealings is ultimately disposed of or transferred in an appropriate manner.
Plans and arrangements should demonstrate:
5.1 Documented procedures to ensure that details of any radioactive waste to be ultimately disposed of or transferred are provided to ARPANSA.
5.2 Compliance with the following where appropriate:
Requirements of appropriate statutory authorities and any local regulations such as Trade Waste Agreements.
5.3 Documentation showing undertakings by other organisations to accept responsibility for controlled apparatus and controlled material when no longer required by the licence holder.
5.4 Provision for consultation with local government and other relevant authorities on all matters connected with ultimate disposal of controlled facilities, controlled apparatus and controlled material.
The licence holder or applicant is responsible for ensuring arrangements are made and implemented for the security of controlled facilities, controlled apparatus and controlled material, to prevent unauthorised access, damage, theft, loss or unauthorised use. The arrangements should include administrative and physical controls and barriers to ensure that the control of these items is not relinquished or improperly transferred, taking account of any relevant requirements imposed by the ARPANS legislation and, where applicable, the Australian Safeguards and Non-proliferation Office.
General security
Plans and arrangements should demonstrate:
6.1 International Standards14 that reflect international best practice for nuclear security are taken into account and the interfaces between security and safety have been considered.
6.2 Procedures ensure that all conduct and dealings with controlled materials, controlled apparatus and controlled facilities are in accordance with RPS 11 Code of Practice for the Security of Radioactive Sources.
6.3 Periodic reviews of inventories to confirm the category or aggregated category of sources in their designated locations.
6.4 Reasonable steps have been taken to ensure such security plans and arrangements are implemented.
6.5 Appropriate security for storage, use and transport (as applicable) of controlled apparatus and controlled material, including:
Details of the storage location
Description as to the authorised use of the source
Provision of a suitable temporary storage area in the event of off-site dealings
Provision of a secure storage area for any radioactive waste awaiting disposal.
6.6 Security plans are updated in a timely fashion in accordance with regulatory requirements; or as necessary to address issues or changes in threat environment identified in the threat assessment.
6.7 Records are kept of any changes made to the security plans and arrangements.
6.8 Clearly defined lines of responsibility for security and of authority for decision-making in matters of security of controlled facilities, controlled apparatus and controlled material.
6.9 A description of arrangements for the provision of security and response to security threats, including: scalable procedural and administrative security measures to meet increased levels of threat.
6.10 Appropriate back-up of security documentation and maintenance of computer security.
Security enhanced sources
Plans and arrangements for security category 1, 2 & 3 sources15 or facilities containing such sources should demonstrate:
A description of the source including details such as isotope, activity and the date of measurement, serial number and physical and chemical form.
A description of the radiation practice for which the source is used and the categorisation of the source calculated in accordance with the methodology set out in Schedule B.
A description of the specific location of the source in the building or facility where it is used or stored.
A plan of the building or facility in which the source is used or stored including the physical security measures used to protect the source and a definition of the secure area for the purposes of Schedule D.
Allocation of responsibilities for security to competent and qualified persons with appropriate authority to carry out their responsibilities.
A description of the specific security concerns to be addressed, for example theft or sabotage, or mechanical or electronic failure of a physical security measure.
A description of the physical security systems that will be used to address the security concerns and meet the requirements of the Code.
A description of the procedural security measures that will be used to address the security concerns and meet the requirements of the Code.
Arrangements for review and revision of the Source Security Plan, including maximum time between reviews in accordance with regulatory requirements.
Measures to effectively respond to a malicious act consistent with the threat.16
The threat assessment developed by the Australian government in consultation with the regulatory body should be used as a common basis for determining security requirements, and evaluating security measures implemented by the operator.17
To the extent possible, that security measures during a response to a nuclear security event do not adversely affect the safety of the personnel.
Plans and arrangements for controlled facilities including nuclear installations18 should include:
6.12 Arrangements for protection against unauthorised removal of nuclear material, noting that:
Nuclear material is radioactive material, which also requires protection against unauthorised removal where there are potentially significant consequences if dispersed or otherwise used for a malicious purpose. Protection requirements against unauthorised removal of nuclear material for potential subsequent offsite radiological exposure or dispersal are provided in IAEA Nuclear Security Series No. 14, Nuclear Security Recommendations on Radioactive Material and Associated Facilities.
Physical protection measures in IAEA Nuclear Security Series No. 13 should be additional to, and not a substitute for other measures established for nuclear safety, nuclear material accountancy and control or radiation protection purposes.19
6.13 When a facility contains nuclear material and other radioactive material, the physical protection requirements for both should be considered and implemented in a consistent and non-conflicting manner to achieve an adequate level of security.
In such cases, the more stringent requirements for physical protection should be applied.
NOTE: Levels of protection defined in IAEA Nuclear Security Series No. 13 are based on categorisation of nuclear material for use in the construction of a nuclear explosive device.20 The physical protection of nuclear material against unauthorised removal for use in a nuclear explosive device and the physical protection of nuclear facilities against sabotage are addressed in IAEA Nuclear Security Series No. 13, Nuclear Security Recommendations on Physical Protection of Nuclear Material and Nuclear Facilities (INFCIRC/225/Revision 5).
International Standards
6.14 International Standards may also be used by ARPANSA in assessing plans and arrangements for the security of radioactive material, associated facilities and activities for the prevention of malicious acts intended or likely to cause harmful radiological consequences. International standards provide additional guidance on elements of a security plan and emphasise a regulatory responsibility to verify compliance with the security plan.21 When a facility contains both nuclear material and other radioactive material, the protective requirements of an number of international standards should be considered and implemented in a manner such that the more stringent requirement for physical protection are applied.22
15 The security category is calculated according to methodology in Schedule B of RPS 11 Code of Practice Security of Sources
16 Nuclear Security Series No. 14 Paragraph 3.33
17 Nuclear Security Series No. 14 Paragraph 4.2
18‘Nuclear Installations’ as defined in Section 13 of the ARPANS Act (1998)
19 Nuclear Security Series 13 Paragraph 3.17
20 Nuclear Security Series No. 13 Paragraph 4.2
21Nuclear Security Series No. 14 paragraphs 4.20 and 4.21 and IAEA Nuclear Security Series No. 13 paragraph 3.27 provide further guidance on the elements of a security plan
22 Nuclear Security Series No. 13 Paragraph 1.15 and IAEA Nuclear Security Series No. 14 Paragraph 1.16
The licence holder or applicant is responsible for providing detailed emergency plans for any conduct or dealing that could give rise to a need for emergency intervention. This plan should be based on an assessment of the consequences of reasonably foreseeable accidents or incidents, and should aim to minimise the consequences and ensure the protection of on-site personnel, the public and the environment.
Plans and arrangements should demonstrate:
7.1 Emergency plans for any conduct or dealing which could give rise to a need for emergency intervention which are consummate with the Emergency Preparedness Category for the facility from RPS G-3 Guide for Radiation Protection in Emergency Exposure Situations.
7.2 Identification of the various operating and other conditions which could lead to the need for intervention.
7.3 Identification of potential incident and accident situations in terms of the hazard, the personnel at risk, and the consequences of potential accidents including environmental impact.
7.4 Classification of potential emergencies in terms of their consequences.
7.5 Suitable intervention and action levels are defined for the relevant protective actions taking into account the possible degrees of severity of accidents that could occur.
7.6 Consideration of a range of intervention measures.
7.7 Identify emergency zones for emergency planning purposes by defining responses to a localised dispersal of radioactive material; or radiological release from a facility.
7.8 The degree of emergency planning is commensurate with the nature and magnitude of the risk, and the feasibility of mitigating the consequences should an accident occur.
7.9 The emergency plan is coordinated with those plans and arrangements prepared by other relevant bodies that have radiological emergency response responsibilities in a nuclear or radiological emergency.
7.10 Responsibilities are specified for the management of interventions on-site, off-site and across state and national boundaries, as appropriate, in all separate but interconnecting plans.
7.11 Integration of emergency plans with other plans and arrangements such that safety and security measures do not contradict each other in emergency situations.
7.12 Intervening organisations have been involved in the preparation of emergency plans as appropriate.
7.13 Allocation of responsibilities for notifying the relevant authorities and for initiating intervention.
7.14 Identification of methods and instruments for assessing the accident and its consequences on and off the site.
7.15 The content, features and extent of emergency plans take into account:
The results of any accident analysis
Any lessons learned from operating experience
Any lesson learned from accidents that have occurred with conducts or dealings of a similar type.
7.16 Training and retraining arrangements for personnel involved in implementing the emergency plans.
7.17 Arrangements for public information releases in the event of an accident.
7.18 Provision for the early prediction or assessment of the extent and significance of any accidental discharge of radioactive substances to the environment.
7.19 Provision for rapid and continuous assessment of the accident, and determine the need for protective actions as the accident proceeds.
7.20 Provision for dissemination of information to members of the public who could reasonably be expected to be affected by the emergency both prior to and during the emergency.
7.21 Provision for protection and mitigation actions, and assigned responsibilities for initiating and discharging such actions.
7.22 Criteria for terminating each protective action are defined.
7.23 Defined actions to be taken during restoration.
7.24 Compliance with current legislation and national and international agreements including reporting to ARPANSA.
7.25 The emergency plan is reviewed and updated regularly taking into consideration the results of the emergency exercises.
Emergency procedures
The licence holder or applicant is responsible for ensuring that comprehensive emergency procedures are prepared in accordance with the objectives of the emergency plan for any conduct or dealing which could give rise to the need for emergency intervention.
Plans and arrangements should demonstrate:
7.26 A statement describing the potential emergency situation to which each procedure applies.
7.27 A statement of purpose for each procedure.
7.28 An organisational structure where the lines of authority and the functions of all individuals who will respond to an emergency are clearly defined.
7.29 The communication arrangements for contacting any relevant on-site personnel and intervening organisations, and for obtaining assistance from fire-fighting, medical, police and any other relevant organisations.
7.30 The actions needed both during emergency and during restoration after the emergency including:
A description of appropriate intervention and action levels
A description of the action sequence to achieve the purpose of the procedure
Specification of the precautions and limitations during the performance of the prescribed tasks
Specification of guidelines to be followed in the exercise of judgement on the part of an individual, either in interpretation of results, action levels, or recommendations of protective actions.
Take into account human performance in demanding circumstances.
7.31 The training requirements for all personnel involved in implementing the emergency plans.
7.32 Copies of examples of forms to be used in carrying out tasks relevant to the procedures.
7.33 Where appropriate, sign-off sheets, checklists and data sheets to document completion of the actions prescribed in the procedures.
7.34 A list of the emergency response facilities and equipment for use in the case of an accident (including radiation monitoring instruments, sampling and counting equipment, personnel dosimeters, personal protective equipment, decontamination supplies, emergency control rooms, communication facilities, maps, facility floor plans and reference material).
7.35 Provisions for all actions related to emergency preparedness (see 7.36 – 7.42).
Emergency preparedness
The licence holder or applicant is responsible for ensuring that all organisations identified in the emergency plan are prepared for such emergencies, and that adequate facilities and equipment are available and maintained.
Plans and arrangements should demonstrate:
7.36 An appropriate rostering system and back-up procedure is in place to ensure that emergency personnel are always available.
7.37 The emergency plan is exercised regularly to:
Test emergency equipment
Test the adequacy of on-site personnel resources
Ensure that personnel understand their responsibilities and relationships within their organisation; and procedures for interfacing with Intervening Organisations.
Test communications and communication equipment
Test evacuation procedures and evacuation routes
Confirm the viability of intervention measures to protect off-site personnel and the environment
Confirm the availability of suitable public information systems
Confirm the availability of external facilities, including those for the provision of medical aid to treat injured and/or radioactively contaminated persons
Test the emergency response interface with government, local authorities and off-site agencies.
7.38 Regular retraining of personnel is carried out in each organisational unit involved in the emergency plan.
7.39 Emergency contact lists and procedures are regularly reviewed and updated.
7.40 Emergency response facilities (including communications) are maintained.
7.41 Calibrated monitoring and sampling equipment for use in the case of an emergency is available.
7.42 A records management system has be established and maintained in relation to emergency arrangements to a radiological emergency in order to allow for their review and evaluation.
The licence holder or applicant is responsible for ensuring that arrangements are in place to demonstrate radiation protection of wildlife (plants and animals) in their natural habitats is consistent with international best practice.
Plans and arrangements should demonstrate:
8.1 Radiation protection of wildlife in their natural habitats has been considered in parallel with radiation protection of people.
8.2 Wildlife populations and ecosystems are shown to be protected using an environmental radiological assessment, consistent with the methodology outlined in RPS G-1 Guide for Radiation Protection of the Environment that:
Considers dose rates to wildlife above natural and normal background level.
Applies a graded approach that is as simple as possible, but as complex as necessary.
Demonstrates characterisation of the radiological source.
Identifies all potential exposure scenarios and pathways to the environment and affected biota.
Is based on the concept of reference organisms.
Documents assumptions made and limitations in methodologies and data, including uncertainties.
8.3 Environmental radiological assessments of wildlife in their natural habitats should be initially benchmarked to a screening dose rate of 10 µGy/h. The screening assessment should be conservative.
8.4 Where the screening dose rate is exceeded a more complex assessment is required that:
Uses less conservative consumptions or site-specific data.
Discusses population size and species likely to be affected, as well as potential impacts on biodiversity.
Is compared to an environmental reference level (ERL) for each affected species type which is based on knowledge of biological effects in wildlife related to dose rate.
8.5 Where a complex assessment still identifies incremental dose rates to wildlife above ERL(s) then further optimisation, including possible mitigation measures, may be required.
Decommissioning refers to administrative and technical actions taken to allow removal of some or all of the regulatory controls from a facility (except for a radioactive waste disposal facility, which is, by definition, subject to closure and not decommissioning). Such actions involve decontamination, dismantling and removal of radioactive materials, waste, components and structures. They are carried out to achieve a progressive and systematic reduction in radiological hazards and are taken on the basis of planning and assessment to ensure safety during decommissioning operations.
While much of the decommissioning activity takes place in the final phase in the lifecycle of the facility, planning for decommissioning nominally begins during facility design and continues through all phases of the facility lifecycle. Experience has shown the importance in considering decommissioning for new facilities at the design stage, developing an initial decommissioning plan, and periodically updating the initial decommissioning plan during and at the conclusion of the operational phase. The subsequent objective is to develop a final decommissioning plan prior to the start of decommissioning activities.
Plans and arrangements should demonstrate:
Consideration of relevant safety and regulatory aspects
Application of a graded approach
Selection of an appropriate decommissioning strategy
Guide to assist a controlled person when applying for a facility licence under section 32 of the Australian Radiation Protection and Nuclear Safety Act 1998.
This guide should be read when completing the Licence Application Form.
Associated forms
Applicants should use the nuclear installation or prescribed radiation facility application form depending on the type of facility:
1.1 Section 30 (1) (e) of the Australian Radiation Protection and Nuclear Safety Act 1998 (the Act) [1] requires that a controlled person[1] must not decommission, dispose of or abandon a controlled facility[2] unless the person is authorised to do so by a facility licence; or the person is exempted in relation to the conduct concerned by regulations made for the purposes of this section.
1.2 Decommissioning refers to administrative and technical actions taken to allow removal of some or all of the regulatory controls from a facility (except for a radioactive waste disposal facility, which is, by definition, subject to closure and not decommissioning) [2]. These actions involve decontamination, dismantling and removal of radioactive materials, waste, components and structures. They are carried out to achieve a progressive and systematic reduction in radiological hazards and are taken on the basis of planning and assessment to ensure safety during decommissioning operations.
1.3 Adequate planning and implementation of decommissioning are required to ensure the protection of the workers, the public and the environment.
1.4 The period for decommissioning activities may typically range from a few months to decades (for example, to allow for radioactive decay) and may include phased release of parts of a site or facility from regulatory control. Dismantling may occur immediately after shutdown or deferred until after a safe enclosure period. On completion of decommissioning and on reaching the desired end state the facility and site will be available for restricted or unrestricted use.
1.5 While much of the decommissioning activity takes place in the final phase in the lifecycle of the facility, planning for decommissioning nominally begins during facility design and continues through all phases of the facility lifecycle. Experience has shown the importance in considering decommissioning for new facilities at the design stage, developing an initial decommissioning plan, and periodically updating the initial decommissioning plan during and at the conclusion of the operational phase. The subsequent objective is to develop a final decommissioning plan prior to the start of decommissioning activities.
1.6 This guidance document is drawn mainly from the IAEA guidance, found in the supporting IAEA Draft Safety Guide: Decommissioning of Nuclear Power Plants, Research Reactors and Other Nuclear Fuel Cycle Facilities [3], on how to meet the requirements of the IAEA General Safety Requirements (Part 6): Decommissioning of Facilities [2]. This document is written in the context of the legislative and regulatory framework of the Commonwealth of Australia for the controlled facilities owned by Commonwealth entities, but can be applied generally in other jurisdictions.
1.7 Terms defined in the Act [1] and the Australian Radiation Protection and Nuclear Safety Regulations 2018 (the Regulations) [4] have the same meaning in this Regulatory Guide. All other terms in this Guide are intended to be consistent with the definitions in the IAEA Safety Glossary [5].
Objective
1.8 The objective of this Regulatory Guide is to provide guidance to licence holder and/or responsible person[3], technical support organisations, and other interested parties on planning, conducting and completing the decommissioning of nuclear installations. It aims to assist in ensuring that the decommissioning of these facilities is conducted in a safe and environmentally acceptable manner in accordance with good international practice. This document is also used for regulatory assessment of a licence application for decommissioning a controlled facility.
Scope
1.9 This document provides guidance on planning for decommissioning, conducting decommissioning actions and terminating the authorisation of controlled facilities, such as research reactors, radioisotope production facilities, spent fuel management facilities and radioactive waste processing and storage facilities, relevant medical and industrial facilities and research and development facilities. This document provides recommendations to assist in fulfilling the basic safety requirements for decommissioning. It includes guidance on the relevant safety and regulatory aspects, application of the graded approach, selection of the appropriate decommissioning strategy, key considerations in facilitating decommissioning during design, construction and operation, development and review of decommissioning plans, main aspects of radiation protection for decommissioning, safety assessment, funding, decommissioning management, transition from operation to decommissioning and termination of the authorisation.
1.10 This Regulatory Guide addresses related considerations and activities for decommissioning from design until completion of decommissioning. On the basis of general considerations regarding safety, radiation protection of human health and the environment and regulatory aspects, this document provides guidance on the selection of a decommissioning strategy, development of initial and final decommissioning plans and implementation of decommissioning management principles. Several key decommissioning tasks are also discussed.
1.11 This Regulatory Guide mainly addresses the radiological hazards resulting from the activities associated with the decommissioning and the management of waste and materials arising from the decommissioning operations, after a planned shutdown. Many of the considerations are also applicable to decommissioning after an abnormal event or an unanticipated shutdown that has resulted in serious damage or contamination. In these cases, this Regulatory Guide should be used as a basis for developing special decommissioning provisions.
1.12 In the event that part of a facility is being decommissioned, this Regulatory Guide only applies to the decommissioning activities. However, the potential safety implications with respect to the interaction between any decommissioning work and any continuing facility operations should be addressed on a case-by-case basis.
Information requested
1.13 Subsection 46(2) of the Regulations [4] gives the CEO the power to ask an applicant for some or all of the information and documents mentioned in the table and other relevant information about the application.
1.14 Under paragraph 53(3)(b) of the Regulations [4], the CEO must take into account whether the application includes all of the information asked for by the CEO, as relevant to the specific stage in the licensing process.
1.15 Section 32(3) of the Act requires that in making decision in relation to an application for a facility licence, the CEO must take into account international best practice in relation to radiation protection and nuclear safety. Information and documents that the CEO asks for in relation to licence application will include information relevant to international best practice. International best practice includes international standards particularly those of the International Atomic Energy Agency (IAEA). The requirements specified in this documents are those of the IAEA General Safety Requirements Part 6: Decommissioning of Facilities [2]. These requirements are internationally agreed general safety requirements on the basis of the fundamental safety objective and fundamental safety principles [6, 7].
2. Protection of Human Health & the Environment
Requirement 1: Optimisation of Radiation Protection and Safety in Decommissioning
The licence holder and/or responsible person and/or responsible person must consider exposure during decommissioning as an authorised planned exposure and the relevant requirements of RPS F-1 and RPS C-1 must be applied accordingly during decommissioning.
2.1 The principles of radiation protection and safety for practices are provided in RPS F-1 Fundamentals for Protection against Ionising Radiation (2014) [6], which is based on the IAEA Safety Fundamentals [7]. The principles of justification of activities causing exposures to radiation, optimisation of exposures, limitation of exposures, and protection and safety being commensurate with the radiation risks, must be applied during decommissioning of controlled facilities. The activities associated with the decommissioning of a facility must be considered to be part of the original practice and the requirements of Code for Radiation Protection in Planned Exposure Situations, Radiation Protection Series C-1 [8] must be enforced during all decommissioning activities.
2.2 During decommissioning, the workers, the public and the environment should be properly protected from radiological and non-radiological hazards. The licence holder and/or responsible person must comply with the exposure limits for workers and the public in Part 6 of the Regulations [4] and the environmental discharge limits specified in the licence. A radiation protection program should ensure that radiation protection of workers and the public is optimised during decommissioning. Optimisation should be implemented, taking into account the specifics of the decommissioning project [2].
2.3 The licence holder and/or responsible person should consider the radiation protection of both workers and the public, not only during the course of decommissioning but also when a site is proposed to be released with restrictions on its future use [2].
2.4 Consideration should be given during decommissioning to protection against and mitigation of potential exposures from incidents or accidents[4]. The licence holder and/or responsible person for a facility that is undergoing decommissioning must manage and control activities to mitigate impacts on the environment of the site and the surrounding area. These arrangements should be maintained during decommissioning and beyond if a facility is released with restrictions on its future use. The required end state conditions must be met before a site or a facility is released with no restrictions.
2.5 The licence holder and/or responsible person should undertake a safety assessment to define protective measures using an optimisation approach for radiological protection with due regard for radiological safety. Such assessment should take into account all relevant hazards, and structures, systems and components (SSCs) (e.g. ventilation system, drainage) and their corresponding safety functions. It should be noted that some of the SSCs will continue to be required during decommissioning and decommissioning can also give rise to the need for new safety functions and SSCs. These need to be considered to ensure overall safety during decommissioning.
2.6 The licence holder and/or responsible person should foster and maintain a holistic approach to safety which addresses the technology, the individual or human, and the organisation, and the interactions between them, to both create and maintain safe operations and reduce the relative risk[5].
2.7 Appropriate training on health, safety and environmental matters should be provided to individuals engaged in decommissioning activities.
2.8 During decommissioning, radioactive and non-radioactive effluents may be discharged to the environment. These discharges must be controlled in compliance with licence conditions and with other requirements of local authorities and State and Territory jurisdictions.
2.9 Radioactive waste management is further discussed in Sections 5 and 8. Radiological criteria for the removal of regulatory control from materials, facilities and sites is discussed in Section 9 and further guidance is provided in other IAEA Safety Standards [10-11].
2.10 The transport of radioactive material must satisfy the Code: Safe Transport of Radioactive Material Radiation Protection Series C-2 (2014) [12], which adopts the IAEA Transport Regulations [13].
Radiation Protection
2.11 A radiation protection plan, for protecting human health and environment, should be included as part of the decommissioning plan and should be based on the national requirements for radiation protection set down in the Code: Radiation Protection in Planned Exposure Situations, Radiation Protection Series C-1 (2016) [8]. Regulatory expectations for the radiation protection plan are found in the Regulatory Guide [14].
2.12 A principal focus of radiation protection during decommissioning activities is the protection of workers against normal and potential occupational radiation exposure. Consideration must be given to the protection of workers undertaking interventions in the event of an emergency. Radiation protection of workers and the members of the public exposed as a result of decommissioning activities must be optimised with due regard to relevant dose constraints.
Graded approach to decommissioning safety
Requirement 2: Graded Approach
The licence holder and/or responsible person must apply a graded approach to all aspects of decommissioning in determining the scope and level of detail for any particular facility consistent with the magnitude of the possible radiation risks arising from the decommissioning.
2.13 The range of decommissioning activities for controlled facilities is broad, and the scope, extent and level of detail of planning, safety assessment and demonstration, preparation, review and update of safety related documentation should be commensurate with the types and magnitude of hazards, and their potential consequences to workers, the public and the environment. Therefore, a graded approach should be applied to the planning, conduct and completion of decommissioning, and release of the site for unrestricted use or with restrictions on its future use [2]. The graded approach should be applied in a way that does not compromise safety and ensures compliance with all relevant safety requirements and criteria.
2.14 The application of the graded approach in the context of controlled facilities should take into account factors such as:
size and type of the facility (including its complexity and consideration of historical burial of waste from past practices);
physical state of the facility, specifically the integrity of the SSCs. In particular, the extent to which ageing or abandonment may have compromised building structures or SSCs, for example, due to a long period of poor maintenance;
radiological (source term), biological and chemical inventories and hazards associated with the decommissioning of the facility;
lifecycle stage of the facility (design, construction, commissioning, operation, shutdown or decommissioning), such as the preparation of an initial decommissioning plan at a design stage or a preparation of a final decommissioning plan prior to planned shutdown;
scope of the safety assessment (e.g. for a part of a facility, a single facility at a multi-facility site or an entire site);
extent to which the proposed decommissioning operations could adversely affect ongoing operations with safety significance elsewhere at the facility or at nearby facilities;
uncertainty of information (e.g. the quality and extent of the characterization of the facility) and the reliability and availability of relevant supporting information (e.g. drawings and records of modifications) to be used as input data for the safety assessment;
complexity of the decommissioning tasks; and
final end state of the decommissioning of the facility (e.g. unrestricted or restricted use).
Assessment of Safety
Requirement 3: Assessment of Safety
The licence holder and/or responsible person must assess the safety of all facilities for which decommissioning is planned and for all facilities undergoing decommissioning.
2.15 The safety assessment should establish the hazard category of the facility and be conducted to the depth and rigour that reflects the hazard categorisation using a graded approach. The rigour of the assessment for the proposed work to be undertaken should be proportionate to the hazard, making more use of judgement. The more serious the potential risk the more onerous is the task of demonstrating that further protection is not needed.
2.16 The safety assessment should be developed and documented by the licence holder and/or responsible person, approved by ARPANSA, and maintained current throughout the decommissioning program.
2.17 More detailed discussion of safety assessment is found in Section 7.
Environment Protection
2.18 The licence holder and/or responsible person must consider environmental protection to enable efficient management of decommissioning and define the controls to ensure that any impact to the environment of the site and the surrounding area is mitigated to the extent practicable within acceptable levels. An assessment of the radiological impact on the environment should be developed concurrently with the decommissioning plan (see Section 5). Environmental protection should be maintained during the entire decommissioning process and beyond if a facility is released with restrictions on future use.
2.19 Environmental monitoring should be conducted throughout decommissioning. All potential radioactive releases should be prevented or controlled at source. Where releases are expected and authorised by ARPANSA the releases should be monitored through identified release points. Off-site monitoring may be conducted to demonstrate the adequacy of the control over releases of radioactive materials to the environment. The Regulatory Guide [14] should also be taken into account in developing the Environment Protection Plan.
3. Responsibilities associated with decommissioning
Requirement 6: Responsibilities of the Licence holder and/or responsible person
The licence holder and/or responsible person must implement planning for decommissioning and must carry out the decommissioning actions in compliance with the ARPANS Act & Regulations and conditions of the decommissioning licence. The licence holder and/or responsible person is responsible for all aspects of safety and protection of people and the environment during decommissioning.
3.1 When a facility is taken out of service the licence holder and/or responsible person is responsible for the safety of the facility during decommissioning until surrender of the licence. The licence holder and/or responsible person should demonstrate that decommissioning can be undertaken safely without undue risk to the health and safety of people and the environment. In developing and implementing the final decommissioning plan the licence holder and/or responsible person should take into account international best practice for protecting people and the environment.
3.2 The licence holder and/or responsible person is responsible for:
selecting the decommissioning strategy as the basis for preparing and maintaining decommissioning plans (initial and final) throughout the life of the facility;
preparing all decommissioning related documents, including the decommissioning plans, safety and environment assessments, and any other information required by ARPANSA;
submitting them for regulatory review and for implementing the authorised final decommissioning plan; and
estimating the cost of decommissioning actions and providing assurances and resources to cover the costs associated with safe decommissioning, including management of resulting radioactive wastes.
3.3 The licence holder and/or responsible person requires to obtain approval from the CEO of ARPANSA prior to conducting decommissioning activities as stipulated in section 30(1) of the Act.
4. Management of Decommissioning
Management System
Requirement 7: Integrated Management System
The licence holder and/or responsible person must apply an integrated management system to all aspects of decommissioning.
4.1 An integrated system for the management and implementation of decommissioning is established as part of the licence holder and/or responsible person’s organisation, with the prime responsibility for ensuring that decommissioning will be conducted safely. The reporting hierarchy and lines of responsibility and authority should be such that they do not create conflicts between organisations and activities that could compromise safety during decommissioning.
4.2 The integrated management system provides a single framework for the arrangements and processes necessary to address all the goals of the licence holder and/or responsible person. These goals include safety, health, environmental, security, quality and economic elements.
4.3 The management system should be appropriate to the size, complexity and impact of the project in accordance with a graded approach (see Section 2), have a quality system, and be continually assessed and improved during decommissioning.
4.4 The licence holder and/or responsible person should plan and apply the management system before the commencement of decommissioning and should extend it to all phases of decommissioning. A description or reference to an approved management system including a definition of its scope and extent should be included in the final decommissioning plan. The management system should include processes for the maintenance and archiving of documents and records relating to decommissioning and the performance of all work activities and operations for decommissioning.
4.5 General guidance on integrated management systems can be found in IAEA Safety Standards Series publications [15]. Guidance on management systems, for more complex decommissioning projects is provided in IAEA Safety Standards Series publication GS-G-3.1 [16] and GS-G-3.5 [17].
Safety management
4.6 Within the integrated management system, safety is the most important issue overriding all other demands [15]. Safety management refers to those aspects of the management system that are put in place to ensure that acceptable levels of safety are maintained during decommissioning.
Holistic Safety
4.7 The management system is key to establishing a system for leadership and management for safety that will provide assurance that the operator has systems and procedures in place to identify, characterise and manage all safety issues including ranking the relative importance of risks so that available resources are deployed efficiently.
The management system should foster and promote a culture of safety which takes into account human factors such as attitudes and behaviour as well as the general mindset by which all workers - including senior management - approach safety. These factors should interact with the technological and organisational factors in a way that promotes holistic safety which is considered a best practice approach to safety management. A holistic approach to safety ensures the technology is safe to use; people perform tasks safely at work; and the organisation overall is managed safely. ARPANSA has developed Holistic Safety Guidelines on the implementation of holistic safety to which applicants should refer.
4.8 Safety management should include such organisational elements as:
definition of the safety policy;
identification of the main responsibilities, authorities and lines of reporting within the licence holder and/or responsible person;
arrangements for developing, regularly reviewing, updating and maintaining a current safety assessment demonstrating that the facility can be decommissioned safely and establishing operating limits and conditions for safety;
arrangements for complying with, and amending, operating limits and conditions for safety;
arrangements for gaining prior regulatory approval for changes having significant implications for safety;
revision and updating the decommissioning plan as necessary;
definition of the activities and competences necessary to ensure safety;
arrangements to ensure that the activities of the licence holder and/or responsible person are conducted safely;
arrangements for approving safety related activities by the operating organisation’s safety approval body and maintaining approvals current;
establishing, implementing and maintaining a program of maintenance, periodic testing and inspection activities that enable safe decommissioning; and
arrangements for maintaining a complete and current inventory of apparatus and radioactive materials controlled under the decommissioning licence.
4.9 The licence holder and/or responsible person should take into account the Management System described in the Regulatory Guide [14].
5. Decommissioning Strategy
Requirement 8: Selecting a Decommissioning Strategy
The licence holder and/or responsible person must select a decommissioning strategy that will form the basis for planning for decommissioning.
5.1 The overall purpose of a decommissioning strategy is to serve as a basis for the decommissioning plan and in turn to achieve the end state of the decommissioning plan. The licence holder and/or responsible person should develop a timely, cost effective strategy, which maintains high standards of protecting people and the environment [2] taking into account internationally accepted approach.
5.2 The decommissioning strategies should consider the two strategies defined by the IAEA namely: immediate dismantling or deferred dismantling. For multi-facility site the licence holder and/or responsible person should consider interdependencies between the facilities both under operation and/or permanently shut-down for decommissioning.
5.3 The licence holder and/or responsible person should justify the selection of a particular strategy and/or a combination of two strategies.
5.4 An evaluation of the various decommissioning strategies should be performed considering a wide range of factors for these nuclear installations. It should be ensured that the selected strategy meets all the applicable safety requirements. The selection of a preferred decommissioning strategy should be made by analysing factors such as [2]:
compliance with the legal framework for decommissioning including adequacy and availability of financial resources, and radiological release criteria;
proposed future use of the facility, site and the area adjacent to the site after decommissioning and the desired end state;
characteristics of the facility, interdependences with other facilities or infrastructure located at the same site;
physical status of the facility for the anticipated duration of deferred dismantling, including, if applicable, an assessment of the integrity of buildings, structures and systems;
availability of expertise, technologies and infrastructure: experienced personnel and proven techniques, including decontamination, dismantling, and remote operating capabilities;
environmental and socioeconomic impact, including public concerns about the proposed decommissioning activities;
facility radiological condition: characterization of the facility, including the design and operational history, as well as the radioactive inventory after final shutdown;
optimisation of radiological protection of workers, the public and the environment; and
adequacy of arrangements for waste management including packaging, transportation, storage and disposal.
5.5 Appendix I provides a process that a licence holder and/or responsible person could use and document in selecting a strategy for decommissioning a controlled facility. The selected strategy should be reviewed periodically in order to ensure that it remains appropriate in response to changing circumstances and influences.
6. Funding
Requirement 9: Decommissioning Funding
The licence holder and/or responsible person must include responsibilities for funding in the decommissioning plan. Such provisions must include establishing a mechanism to provide and ensure adequate financial resources for safe and timely decommissioning
6.1 The licence holder and/or responsible person needs to demonstrate that adequate financial provisions are available for decommissioning the facility in accordance with the regulatory framework. The cost of decommissioning should reflect all activities described in the decommissioning plan e.g. activities associated with planning for decommissioning, transition from operation to decommissioning, conduct of decommissioning; and associated regulatory costs. The decommissioning costs should be based on an end state of unrestricted release of the site, unless ARPANSA has approved the restricted release option for the specific facility. Additional information on estimating decommissioning costs is provided in other IAEA publications.
Note: Regulation 41(e) requires the licence holder and/or responsible person to show the capacity to comply with relevant regulatory requirements and conditions of the licence.
7. Decommissioning planning
Requirement 10: Decommissioning Planning
The licence holder and/or responsible person must prepare a decommissioning plan and maintain it throughout the lifecycle of the facility to show that the decommissioning can be accomplished safely to meet the defined end state
7.1 Decommissioning should be facilitated by planning and preparatory work undertaken during the entire lifecycle of the facility [2] as shown in Figure 1 [3]. This work should be aimed at minimising the potential exposures of workers and the public, protection of the environment during decommissioning and reaching a desired end state to allow the release of the facility from regulatory control.
7.2 A decommissioning plan outlining the overall decommissioning strategy need to be submitted to ARPANSA for approval as part of the application for the operation and decommissioning of the facilities.
7.3 For new facilities, an initial decommissioning plan should be submitted at the time of the licence application for construction. The plan should demonstrate: the feasibility of decommissioning the facility to achieve the desired end state; that the design of the facility appropriately considers and facilitates decommissioning; radiation protection to workers and the public; and minimises environmental impacts and waste generation, during decommissioning.
7.4 For existing facilities that do not have an approved initial decommissioning plan, a decommissioning plan should be prepared as soon as practicable and submitted for regulatory review (e.g. prior to final shutdown) in accordance with the licence conditions.
7.5 Controlled facilities that have been operating for many years might not have considered decommissioning at the design stage or during construction. This should be recognised in the planning for decommissioning for these facilities and preparations for decommissioning should start as early as practicable. Modifications to structures and systems should incorporate features that will facilitate decommissioning and enhance radiation protection to workers and the public and minimise environmental impacts and waste generation during decommissioning.
7.6 For multi-facility sites, the licence holder and/or responsible person should have an overall strategy for decommissioning the site that takes into account the interdependencies of the individual facilities, the associated constraints and the individual facility decommissioning plans [2].
7.7 The licence holder and/or responsible person must submit a safety assessment supporting the final decommissioning plan to ARPANSA. The extent of the safety assessment, its content and the degree of detail may vary depending on the complexity and hazard potential of the facility.
7.8 Historical records are essential to the planning of decommissioning. They should be kept throughout the lifecycle of the facility including siting, design, construction, and operation including modifications and shutdown.
Figure 1: An example of decommissioning plan during the lifetime of the facility
Siting, design, construction and commissioning
Site baseline radioactivity
7.9 The application for a licence to prepare site for a controlled facility should be accompanied by the results of a baseline radiological survey to establish the baseline levels of radiation and for use in assessing the future impact of the facility. The results should identify the key radionuclides and media (e.g. building material, soil and groundwater) to be measured that could be utilised for:
evaluating the impact of the operation of the facility;
determining the acceptability of decommissioning proposals (e.g. strategy and initial plan); and
establishing and demonstrating compliance with an approved end state for the decommissioned facility.
Facilitating decommissioning
7.10 During siting, design, construction and commissioning phases of a new facility, the licence holder and/or responsible person should consider and implement features that facilitate decommissioning of the facility. Relevant features and aspects that should be considered include:
minimising the number and size of contaminated areas, including compartmentalization of processes, to facilitate clean-up during decommissioning;
facilitating access to process equipment, structures, systems and large components;
equipment for facilitating dismantling, demolition, and disposal (such as appropriately rated cranes);
using modular construction in order to facilitate the dismantling of structures, systems, and components not subject to ready decontamination (such as for easily separating mechanical and electrical components);
providing for easy detachment, handling and remote removal of components that may become significantly activated;
using layered or segmented concrete to ease demolition tasks and help separation of contaminated or activated material;
providing for suitable access and egress routes for larger radioactive and contaminated items (this includes the location and size of access doors and/or oversize doors or hatches to remove components or install shielding), and adequate space around equipment for easy movement and working of personnel and/or tooling;
minimising the use of underground pipework and of embedded pipes in the building structures;
minimising the release of radionuclides during the decommissioning process and optimising radiation doses;
using materials that facilitate decontamination, are resistant to activation, are resistant to degradation by chemicals and have sufficient wear resistance to minimise the spread of activated corrosion product;
facilitating ease of decontamination of equipment and surfaces, including built-in decontamination mechanisms, such as protective coverings, bunds and liners in process cells and areas where liquids may be present;
enabling remote decontamination, maintenance and monitoring where necessary;
designing to avoid undesired accumulations of chemical or radioactive materials, and utilising processes that minimise and reduce the volumes of waste;
enabling operational and temporarily stored wastes to be easily retrieved;
providing adequate operational monitoring of vessels, the ground and water ways to detect leaks or releases early enough for effective mitigation; and
minimising the use of hazardous substances that could result in mixed hazardous waste.
7.11 ARPANSA’s assessment of an application to construct a controlled facility takes into account appropriate design features to demonstrate the feasibility of safely decommissioning of the proposed facility to achieve the desired end state.
Initial decommissioning plan
7.12 The initial decommissioning plan should be consistent with the decommissioning strategy but will be limited in detail because the full information will not be available until facility operations cease.
7.13 The initial plan should be submitted to ARPANSA in support of an application for licence to construct and/or operate the facility. This plan should include discussion of:
the selected decommissioning strategy, including the proposed end state of the decommissioned facility;
the key decommissioning tasks and related basic safety issues;
the radioactive waste management approach;
measures taken during the design and construction stages to facilitate decommissioning;
measures that will be taken to preserve skills and knowledge of the facility (i.e. knowledge management) and historical data and access to data;
results of the radiological monitoring program of the site and surrounding area of the proposed facility, establishing the environmental baseline levels of radiation prior to facility’s construction and before operation; and
preliminary estimated cost of decommissioning the facility and the means of financing.
7.14 The existing facilities and equipment that could potentially be used during decommissioning should be identified early in the initial planning phase.
Update of initial decommissioning plan
7.15 The licence holder and/or responsible person should review the initial decommissioning plan and update it periodically during facility operations and as required by the Act, Regulations and licence conditions. The revisions should include consideration of:
changes to the decommissioning strategy;
changes in the proposed decommissioning end state for the site;
changes in financial conditions or requirements;
design or process modifications to the facility;
operational and decommissioning experience feedback;
availability of waste disposal capacity and acceptance criteria for waste disposal;
new or revised safety requirements;
new or revised regulatory requirements;
technological developments in decommissioning techniques;
plant life extension; and
Incidents or accidents, changing the radiological inventory estimation.
7.16 Surveys of the facility should be conducted to determine inventories and locations of radioactive, fissile and other hazardous materials. The degree and extent of radioactive contamination that has occurred during operation should be clearly determined, characterised, classified, recorded and evaluated with regard to the decommissioning plan. An accurate characterisation of the facility is essential input for the safety assessment (including the criticality analysis, if needed) to be developed for the final decommissioning plan.
7.17 During each update of the initial decommissioning plan, the existing facilities and equipment identified for decommissioning should be reassessed as to their viability to support the proposed decommissioning activities and the proposed end states.
Records
7.18 Records pertinent to initial decommissioning plan, updating the decommissioning plan and preparation for the final decommissioning plan should be used for effective and efficient decommissioning of the facility.
Appropriate records and documentation related to operating history of the facility include:
design specifications and information from the siting, construction and commissioning, including as-built drawings, models, videos, photographs, piping diagrams, cable penetrations, material specifications, and other details helpful for decommissioning purposes;
details of the weight, size, composition and location of equipment (including experimental devices, piping, penetrations, reinforcement bars) and impurities in their construction materials;
fuel failures and fuel accounting;
incidents leading to spillage or inadvertent release of radioactive material, including the recording of actions, corrective measures and close out;
radiation and contamination survey data, particularly for plant areas that are rarely accessed or especially difficult to access;
releases of radioactivity that could potentially affect surface and ground water, and soil and sediment;
radioactive source terms; and
radioactive wastes and their location, quantity, form and activity.
Records of modifications and changes to the design of the plant, and maintenance experience including:
updated ‘as built’ drawings, videos and photographs, including details of the materials used;
evaluation and records of modifications and changes with respect to their future implication to decommissioning;
special repair or maintenance activities and techniques (e.g. effective temporary shielding arrangements or techniques for the removal of large components);
details of the design, material composition, and the history and location for all temporary experiments and devices; and
changes in operational feed and processes.
Results of on-site and off-site radiological and environmental monitoring of soil and sediment, and ground and surface water;
Records of on-site disposal of operational waste; and
Event management, including the recording of actions, corrective measures and close-out information.
Unanticipated final shutdown
7.19 If the final shutdown of a facility is unanticipated (e.g. due to operational or financial viability, or an accident) the facility should be brought to a safe configuration by the licence holder and/or responsible person. The decommissioning strategy and initial decommissioning plan must be reviewed in light of the causes of the unanticipated final shutdown and the consequences of and effects on the condition of the facility. Any remedial actions required as a result of the unanticipated final shutdown should be done under the operating licence. However, the funding allocated to decommissioning the facility must be reviewed and its adequacy made certain.
Transition from operation to decommissioning
7.20 The transition from operation to decommissioning of a facility generally starts after the final shutdown (or cessation of operation) and may already cover parts of the preparatory activities for decommissioning. The end of the transition period is defined by regulatory approval of the final decommissioning plan and the issue of a licence to decommission the facility.
7.21 Some activities to facilitate decommissioning may be carried out under the operating licence or possess and control licence after final shutdown of the facility. The licence holder and/or responsible person must obtain prior approval from ARPANSA for these activities. Such activities could include:
removal of spent fuel, operational wastes and residual fluids;
facility modification and preservation of systems to facilitate decommissioning;
decontamination of structures and system that may involve removal of structures and systems (e.g. ion-exchange columns, pipework etc.) from its position and take it to a location suitable for the tasks; and
characterisation of the site and facility which may involve removal of components for characterisation of the facility.
Final decommissioning plan
Requirement 11: Final Decommissioning Plan
The licence holder and/or responsible person must prepare and submit a final decommissioning plan to ARPANSA for approval prior to conducting decommissioning actions
7.22 Before the final shutdown of a facility, the licence holder and/or responsible person should confirm the decommissioning strategy and initiate studies to accomplish that strategy in support of developing the final decommissioning plan. These studies should identify the existing systems, equipment and infrastructure (e.g. cranes, space conditioning and waste management systems) that will need to be maintained and used during decommissioning and also identify any new systems that will need to be installed prior to decommissioning.
The final decommissioning plan should address the elements presented in Appendix II.
7.23 The final decommissioning plan should present information describing the proposed decommissioning tasks including decontamination, dismantling, clean up and demolition of structures, systems and components; and remediation of surface and ground water, soil and sediment.
Records and reports of decommissioning
7.24 Provisions should be made in the final decommissioning plan for maintaining records of each task carried out in the decommissioning process. Accurate and complete information concerning the locations, configurations, form, quantities and types of radionuclides remaining in the facility is essential and should be acquired and maintained. These records could be used to demonstrate that on completion of decommissioning all radioactive materials that were present at the beginning have been properly accounted for with their ultimate destinations and uses identified and confirmed. This documentation should also account for materials, structures and land that have been removed from regulatory control.
Phased approach to decommissioning
7.25 For a larger decommissioning project, a phased approach is generally implemented to reach the objectives of the final decommissioning plan. The final decommissioning plan and the related phased approach should be supported by an overarching safety assessment report.
7.26 As an example, decommissioning based on immediate dismantling strategy could consist of the following phases:
Phase 1: Removal of radioactive waste and dangerous substances used and produced during the operating life of the facility (when this has not been done during the transition phase between operation and decommissioning
Phase 2: Preliminary operations to prepare the dismantling work (e.g. new working areas, supporting facilities, interim storage of wastes, etc.)
Phase 3: Dismantling operations in order to reduce the source term of the facility
Phase 4: Final clean-up activities (of buildings, etc.)
7.27 The phases could occur in parallel according the final decommissioning plan with each phase subdivided into discrete work packages or projects. The success of implementation of a phased approach is linked to the definition of clear objectives for each specific phase and the work packages making up the phase. The final decommissioning plan should define the starting and ending points of each phase and contained work packages that render the facility in an acceptable stable and safe state and have to be verifiable.
Schedule and sequence of decommissioning tasks
7.28 The final decommissioning plan should provide a schedule for decommissioning phases, including the work packages within the phases and the time period required for completing the entire decommissioning. In developing the decommissioning schedule, the following matters should be considered:
The timing of the start of decommissioning and the sequence in which decommissioning is carried out to optimise the dose received by occupational personnel. This should include the consideration of decommissioning the facility as soon as practicable following final shutdown so that the experience of staff with a working knowledge of the facility may be available to facilitate decommissioning and decommissioning is not unduly delayed (perhaps for economic reasons) in a way that compromises safety.
Ensuring that decommissioning activities that generate radioactive waste are not started until waste disposal or storage facilities are available.
In the case of a nuclear reactor, the early removal of major radioactive sources such as nuclear fuel, heat transport and other process fluids and contaminated materials is considered. If the activity of a component is due mainly to relatively long-lived radionuclides, such as 137Cs, then decontamination or removal of the component early in the sequence might reduce occupational, public and environmental exposures. On the other hand, if high activity comes from short-lived radionuclides, then delayed removal for few years could be considered.
Milestones and hold points such as:
removal of contaminated coolants and other readily removable contaminated and activated materials, including any stored radioactive waste;
when systems containing radioactive material are in a stable condition and sealed;
removal from service of ancillary non-essential systems; and
regulatory inspection hold points required by ARPANSA (e.g. on completion of decommissioning phases or work packages).
Safety Assessment
7.29 The final decommissioning plan must be supported by a safety assessment addressing the planned decommissioning activities and potential abnormal events and accidents that could occur during decommissioning. It should consider occupational, public and environmental exposures.
7.30 The safety assessment must employ a systematic methodology to demonstrate compliance with safety requirements and criteria for decommissioning, including for the release of materials, buildings and sites from regulatory control. In addition, the safety assessment should be used to help ensure that interested parties are confident of the safety of decommissioning [18].
Overarching safety assessment report and detailed safety assessments
7.31 An overarching safety assessment report should address the main safety issues and objectives of the final decommissioning plan and its phases. Based on the outcomes from the overarching safety assessment report, the licence holder and/or responsible person should develop detailed safety assessments for each phase to demonstrate safety of activities foreseen in a given phase.
7.32 In addition, a given phase can be subdivided into discrete work packages or projects for which specific safety assessments can be performed. Detailed safety assessments for the first phases should be performed during the transition period while detailed safety assessment for the others phases may be performed later but prior to the beginning of such phases.
Safety assessment framework
7.33 In all phases of decommissioning the workers, the public and the environment must be protected from hazards resulting from the decommissioning activities for both normal and abnormal situations. Safety assessments contain an analysis of radiological hazards associated with decommissioning activities and demonstrate compliance with the regulatory requirements and criteria. Non-radiological hazards should be evaluated when radiological safety is impacted.
7.34 The depth and rigour of the overarching and detailed safety assessments should be commensurate with the complexity and potential hazard of the facility and its decommissioning and in case of deferred dismantling should take into account the safety of the facility during the period leading up to final dismantling.
7.35 Analyses of accident scenarios should be performed and protective measures should be proposed for preventing accidents or minimising the likelihood of their occurrence and for mitigating their potential consequences. Protective measures are either engineered or administrative controls that provide the necessary radiological protection. The protective measures may require changes to the existing safety systems that were used during operation of the facility. The acceptability of such changes should be clearly justified in the safety assessment.
7.36 The aim of the safety assessment is to determine the necessary safety functions during decommissioning and the related structures, systems and components (SSCs) important to safety in accordance with a graded approach. SSCs important to safety provide the means for preventing the occurrence of postulated initiating events that could lead to incidents or accidents, the control and limitation of accident scenarios, and mitigation of the potential consequences of accidents. In addition, the requirements for maintenance or replacement of systems for mechanical handling, ventilation, power supply and waste handling should be considered in the safety and engineering assessment.
7.37 Postulated initiating events that could lead to elevated radiation levels or release of radioactive material and associated hazardous substances should be identified. The resulting set of identified postulated initiating events should be confirmed to be comprehensive and defined in such a way that the events cover credible failures of the SSCs of the facility, and human errors that could occur during decommissioning activities. The set of postulated initiating events should consider both internal and external events.
7.38 Human factors are an important aspect of the safety of controlled facilities as the state of the facility changes frequently with decommissioning activities. A systematic safety approach should be implemented in order to minimise human errors (built in controls and procedural and equipment protective measures to workers to avoid the risk of contamination). The safety assessment should consider the human errors according to the complexity and hazard potential of the facilities concerned (e.g. large numbers of equipment, tanks, pipes and valves with unexpected remaining radioactive materials and contaminated liquid).
7.39 The likelihood of bounding external events should be assessed taking into account the decommissioning strategy and the site characteristics (e.g. seismic risks, flooding, extreme temperatures, influence from or dependence on any neighbouring facilities) and the likelihood of potential initiating events for incident/accident scenarios (e.g. human error, fire, flood, dropped loads, building/structure collapse/failure, and chemicals).
7.40 Dismantling may involve the deliberate destruction and removal of engineered SSCs that had fulfilled specified safety functions during operation of the facility (e.g. containment, shielding, ventilation, and cooling). If these safety functions are still required during decommissioning the associated SSCs should be maintained in an appropriate state. If this is not practicable these functions should be provided by suitable alternative means or SSCs (e.g. tents, temporary facilities, fire systems, electrical systems, and administrative procedures) for as long as the function is required on the basis of the safety assessment. The appropriateness of alternative means of fulfilling such functions should be demonstrated to the extent practicable. Procedures for changing safety functions during decommissioning should be justified and demonstrated in advance of their implementation.
7.41 Implementation of the safety assessment results should lead to defining operational limits and conditions (OLCs). OLCs are the set of rules that establish parameter limits, functional capability and performance levels required of equipment and personnel for safe decommissioning of the facility. The OLCs could include the required intervals for periodic testing and inspection of SSCs important to safety.
Consideration of radiological and non-radiological hazards in the safety assessment
7.42 The licence holder and/or responsible person should consider the following when assessing the radiological and non-radiological hazards during decommissioning of a controlled facility:
presence and nature of all types of contamination;
hazards associated with the possible in-growth of radionuclides (such as americium);
potential for criticality hazards associated with the possible accumulation of fissile material during operation or during decommissioning activities;
complexity of strategies for waste management due to the diversity of waste streams;
for multi-facility sites, hazards associated with facilities that are not decommissioned;
inaccessible areas and buried pipes;
separation and concentration of material stored in tanks;
hazardous chemicals located in SSCs, in the building, soil and sediment and surface and groundwater;
changes in chemical and physical forms; and
non-radiological hazards, such as fire or explosion, associated with both the operations and decommissioning activities.
Protection against radiological hazards
7.43 After the cessation of operation, preparation for decommissioning often involves the removal of residual radioactive material and operational waste. Even after this step the total amount of contamination remaining within the facility may still be significant and should be taken into account in the safety assessment.
7.44 In the planning stage for decommissioning the degree and extent of contamination in a nuclear installation should be clearly determined, characterised, evaluated and classified. Surveys should be conducted to determine the inventories and locations of radioactive and other hazardous materials. An accurate characterisation of the facility will provide the input for the safety assessment.
7.45 Radiation exposures that could occur during decommissioning must be considered in the safety assessment. This should include external exposure from direct radiation and other radiation sources, potential criticality, internal exposure due to inhalation, ingestion or cuts and abrasions, and loss of containment leading to the uncontrolled release of radionuclides.
Shielding
7.46 Protection against external exposure should be achieved by means of engineered provisions, such as adequate shielding and the use of remote handling equipment, and procedural and work controls. Radiation levels must be monitored to ensure that radiation exposures are within acceptable levels and so that any abnormal conditions would be detected and workers may be evacuated. Areas of potential exposure including ‘hot-spots’ for workers should be appropriately identified and marked.
Confinement
7.47 During decommissioning the control of contamination is provided by confinement and leak detection. Confinement is achieved by means of physical barriers (e.g. static containment) and/or dynamic containment (e.g. by ventilation).
7.48 When dismantling process equipment, respiratory protective equipment of workers may be prescribed. In this case, respiratory protective equipment becomes the barrier which protects the operator from contamination. This equipment must be managed to ensure its functionality and compliance to regulatory requirements.
Criticality safety
7.49 A balance between the assumptions undertaken to perform the criticality safety assessment for decontamination activities and the flexibility in the choice of decontamination techniques and procedures should be reached. Decontamination of equipment (such as highly contaminated glove boxes lines) could lead to the accumulation of fissile material during decommissioning or to the introduction of additional moderators.
7.50 A criticality safety assessment to ensure safety during waste treatment, conditioning and storage of waste packages and liquids should be performed.
Radioactive decay heat and radiolysis
7.51 Heat generation should be taken into account during decommissioning due to the presence of high activity material (solid or liquid) in the facility.
7.52 During decommissioning of radioisotope production, spent fuel management facilities and waste storage facilities, special attention should be given to the difficulty in opening, characterisation, retrieval, and clean-up of storage tanks for highly radioactive liquid waste. Retrieval of the highly contaminated sludge with unknown or unexpected chemical and physical form should also be assessed as should the condition of solid wastes e.g. irradiated fuel, stored for long periods.
Consideration of non-radiological hazards in the safety assessment
7.53 The safety assessment may identify a number of potentially significant non-radiological hazards, which may have radiological consequences during the decommissioning of the facility. These may include the lifting and handling of heavy loads; potential for drop of loads; the use of hazardous materials during the activities for decontamination and dismantling; adequacy of fire protection, especially during dismantlement; and structural integrity of buildings.
7.54 Design considerations should be made for fire safety on the basis of a fire safety analysis. Special attention should be given to the use of thermal cutting techniques (e.g. plasma cutting) and non-thermal cutting techniques (e.g. using grinder and saw) and the associated risk of fire during dismantling especially when mobile confinement tents and personal protective equipment are used.
7.55 Chemical, toxic, flammable or explosive substances can affect safety during decommissioning. To prevent this from occurring the following matters need to be considered during decommissioning:
requirements and guidance contained in international and national standards and guidance on chemical safety;
chemical compatibility of materials that are likely to come into contact;
safe storage of hazardous materials for decontamination activities;
detection and alarm capability for chemical or toxic releases;
electrical safety;
minimization of inventories; and
personal protective equipment to protect against exposures to chemical compounds or toxic materials.
7.56 Although the method for dealing with most of the non-radiological hazards should be managed according to regulations, a strong holistic approach to safety will help to ensure that such hazards are identified and adequately controlled.
Radiation protection resulting from safety assessment
7.57 For facilities which have been inoperable for a long period of time before decontamination or dismantling begins a survey of equipment and buildings should be made to assess hazards associated with the possible deterioration of SSCs. In addition, considerations should be given to the materials of physical barriers and process equipment for which mechanical properties may have changed during operation due to factors such as fatigue (e.g. from cyclic mechanical or thermal loadings), stress corrosion, erosion, chemical corrosion or the induction of changes by irradiation. Decontamination activities implemented during decommissioning should consider the risk coming from the aging of physical barriers and process equipment.
7.58 If suitable alternative means (e.g. mobile tents and administrative procedures) are necessary when dismantling process equipment and physical barriers, the nature and number of the alternative means and their performance should be commensurate with the degree of the potential contamination hazards. Special attention should be paid to the potential dispersion of residual alpha emitters. In many situations mobile tents may become the first confinement barrier during decommissioning. The design of this first confinement barrier should be described in the safety assessment and justified (e.g. static confinement, ventilation, filtration systems, fire and mechanical resistance). The associated SSCs should be defined within the safety assessment and taken into account in the OLCs.
Conducting Decommissioning Actions
7.59 This phase is the implementation and execution of the final decommissioning plan. Activities associated with decommissioning are described in Section 8 which discusses surveillance and maintenance, selection of decommissioning techniques, decontamination, dismantling, demolition, soil and sediment and surface and groundwater remediation, waste and material management during decommissioning, and surveys and inspections.
Update decommissioning-related documentation
7.60 The final decommissioning plan, safety assessment and environmental impact assessment should be treated as living documents consistent with regulatory requirements. They should be modified throughout the course of facility decommissioning to reflect the current decommissioning strategy, facility status, and anticipated activities and work packages.
7.61 As decommissioning is undertaken there may be modifications to decommissioning activities resulting from the collection of new data, unexpected events, feedback of experience and other factors. To reflect this the final decommissioning plan and the related supporting documentation may subsequently need some revisions, amendments or further refinements during implementation as the decommissioning activities progress. These changes may have significant implications for safety and if so require prior approval by ARPANSA under Regulation 51 [4].
7.62 Such a situation may be expected when the phased approach is applied and there are significant periods of time between the decommissioning phases (e.g. deferred dismantling with a long safe enclosure period). Full details should be provided in the plan and associated documentation for the next phase of decommissioning with subsequent phases addressed in less detail. However, the licence holder and/or responsible person is expected to provide full details for each phase before it starts.
7.63 Experience gained during a decommissioning phase could give rise to new data, information or ways of undertaking decommissioning tasks and require the modification to planning for subsequent phases. In such cases, subsequent sections of the decommissioning plan and associated documentation should also be reviewed and updated. The experience from previous decommissioning phases should be appropriately taken into account.
Update of final decommissioning plan
7.64 In the case of complex decommissioning projects such as the decommissioning of nuclear research reactor it is possible that site conditions or circumstances may arise which the final decommissioning plan did not contemplate. To address this situation the final decommissioning plan should include an approved change control process. This should define categories of changes to the final decommissioning plan and associated documentation which have significant implications for safety and need prior approval under Regulation 51 and which allows minor changes with no such implications to be made directly by the licence holder and/or responsible person under Regulation 52 [4]. Typically, prior approval is required for any changes to the final decommissioning plan that would potentially result in a greater radiological hazard during or following decommissioning than was previously approved. Minor modifications to the final decommissioning plan to reflect current project or licence holder and/or responsible person status could be implemented on a periodic basis.
Update of safety assessment
7.65 The licence holder and/or responsible person should review or prepare further safety assessments whenever the final decommissioning plan is revised or additional specific decommissioning work planning documents have been prepared to ensure the conclusions are still valid.
Update of environmental impact assessment
7.66 The effects of modification of any decommissioning tasks or techniques on the environmental impact assessment should be considered. The environmental impact assessment should be updated when a previously unconsidered potential environmental impact is identified. The environmental impact statement should take into account requirements of applicable legislation.
Update of site and facility characterisation
7.67 Information related to site and facility characterisation should be collected over the lifecycle of the facility and details of such information should be addressed in the final decommissioning plan.
7.68 A characterisation report should be prepared which documents the information and data obtained during the characterisation process. The characterisation report should be summarised or referenced in the decommissioning plan. It should be reviewed and approved by ARPANSA and available for audit and/or inspection.
8. Conducting decommissioning
Requirement 12: Conduct of Decommissioning
The licence holder and/or responsible person must implement the final decommissioning plan including management of radioactive waste.
8.1 Conducting decommissioning actions is the implementation of the decommissioning strategy, activities and tasks described in the decommissioning plan. The conduct of decommissioning includes preparatory work related to decommissioning as well as specific decommissioning tasks.
Preparation for decommissioning
8.2 The licence holder and/or responsible person needs to maintain the facility in a safe status during the post operational phase. Depending on circumstances some of the aspects described in this section may be conducted during transition from operation to decommissioning. The transition period from operation to decommissioning could be covered by the licence to possess or control a controlled facility.
Removal of residual process material
8.3 Significant amounts of residual process material may be present in both planned and unplanned locations at the time of final shutdown. This material may consist of new and spent fuel, experimental and irradiation rigs and targets, and operational waste, as well as residual fluids. The removal of this material should be considered as part of the transition from operation to decommissioning or part of decommissioning. These activities can be undertaken under operating licence.
8.4 The handling, storage and disposal of spent nuclear fuel and control absorbers should be addressed, including consideration of criticality of fuel in storage, shipment and disposal. Where relevant, the products of conditioning and preparation of fuel should be taken into account and, if the fuel is to be shipped, the availability of suitable ships and approved transport packages should be addressed. Management of spent fuel is more completely described in relevant IAEA safety guides.
8.5 The hazard associated with the radioactive inventory in irradiation rigs and experimental equipment requires particular consideration due to their portable nature. Measures should be in place to prevent them being improperly removed. Consideration should be given to their removal and disposal at an early phase in the decommissioning process when rig handling equipment and expertise may be in their most efficient state. Records should be maintained of rigs that have been removed and where they are located.
8.6 Timely removal of the residual process materials reduces the requirements for monitoring and surveillance. Other activities associated with decommissioning such as characterisation may be conducted concurrently with the removal of residual fluids but potential interactions should be identified and assessed.
8.7 Residual material and operational radioactive waste should be removed from the facility prior to shutdown, as the safety implications for some of the decommissioning tasks will be less onerous and the SSCs will be characterised accordingly. If operational wastes or residual fluids remain, the safety assessment for the decommissioning tasks may be more complex and may make the decommissioning activities less efficient and increase doses to the operators.
8.8 Even when the bulk of the residual process material has been removed a significant amount of radioactive activation and contamination may remain in the process systems. Preliminary clean-up or decontamination of process equipment may be performed during transition,
8.9 Consideration should be given to physical protection measures. For example, when it is not possible to remove the spent fuel and some operational wastes from the facility, an option could be to move it to a designated storage area within the facility and downgrade the physical protection measures in other areas of the facility.
System decontamination
8.10 From a radiological point of view, it may be appropriate to carry out full circuit decontamination of piping systems before preparing the final decommissioning plan or conducting decommissioning. This could have the benefit of reducing the workforce doses and might also provide for a wider range of techniques for dismantling and related waste management routes e.g. the compliance with transport requirements for large components and allowing external treatment.
Historical site assessment and operational history
8.11 Baseline monitoring should be performed for all new sites/facilities as well as for new facilities on existing sites or for reuse of an existing site. The availability of base line survey information is essential for site/facility characterisation but may not exist. In such cases a baseline measurement should be performed as soon as it is recognised that such measurements are missing.
8.12 A historical site assessment should be performed and information surveys should be undertaken during the lifecycle of the facility and during transition from operation to decommissioning. Information surveys should cover the following:
personnel interviews (with current and previously employed personnel);
operational information including waste management;
facility safety reports;
facility modification reports;
event reports; and
baseline and earlier environmental and facility surveillance reports.
8.13 The results of the historical site assessment should be then used as basis for conducting the radiological characterisation.
Radiological characterisation
8.14 Radiological characterisation establishes the inventory of radionuclides in materials that will require storage or disposal as radioactive waste or release from regulatory control and provides information needed to plan decommissioning activities, including:
the scheduling and workforce requirements particularly with respect to exposure in the most radioactive areas;
the need for protective equipment, shielding and remote operations;
decontamination of SSCs;
dismantling and removal of components and equipment;
demolition of structures; and
management of decommissioning waste.
8.15 The characterisation should include quantitative estimates and records of the type, amount, chemical and physical form, and location of important radionuclides, contaminated materials and other toxic and hazardous materials (such as beryllium, asbestos, inflammable and explosive materials) within the facility at the commencement of decommissioning. The information should be recorded and maintained throughout the various phases of the decommissioning process and after decommissioning as historical records.
8.16 The quantitative estimates for radionuclides, contamination, toxic and hazardous materials should be of suitable accuracy. Where these cannot be obtained directly, reasonably accurate estimates are required. Calculated estimates of radionuclide inventory should be verified, wherever practicable by means of direct measurement. In the case of nuclear reactors, various computer codes are available for calculating the induced activity in a reactor and its immediate surroundings to estimate the radioactive inventory.
8.17 Comprehensive characterisation of the radiological inventory comprises the following steps:
review of historical information;
implementation of calculation methods;
preparation of the sampling and analysis plan based on an appropriate statistical approach;
performance of in-situ measurements, sampling and analysis;
review and evaluation of the data obtained; and
comparison of calculated results and measured data.
8.18 In the case of research reactors, the radiological characterisation must include:
residual radioactivity in the reactor systems, experiments facilities, irradiation rigs, control absorber, and undrained pockets in process circuits;
radioactivity induced by neutron activation, such as 94Nb, 60Co and 55Fe, in a reactor’s internal core structure, experiments facilities, irradiation rigs, and equipment inside the main biological shield of radioactive elements;
radioactive substances deposited as contamination on the internal and external surfaces of various systems, including contamination from fuel, experiments facilities, irradiation rigs, and control absorbers;
daughter radionuclides that become significant after periods of decay should be considered;
residues of nuclear fuel, control absorbers, heat transport fluids and process fluids; and
consideration of radioactive materials that are absorbed by or adhering to facility systems.
8.19 A fully detailed and accurate characterisation might not be possible at the beginning of decommissioning and this should be continually developed and improved as decommissioning progresses. However, detailed and accurate characterisation relevant to a particular decommissioning task must be available to allow final planning of the task before the task is undertaken.
8.20 Before and during decommissioning, an adequate number of characterisation surveys should be conducted to determine the radionuclides, maximum and average dose rates, and contamination and activation levels throughout the facility and in the soil, sediments and ground and surface water. Contamination and activation levels should be determined for the inner and outer surfaces of equipment and in soil and sediments.
8.21 Special surveys may be required to determine the penetration depth in concrete structures, soil and sediments and extent of contamination which is needed for the selection of appropriate decommissioning techniques and methods. For completeness, contamination in shielded or self-shielded components such as inside pipes and equipment and in buildings as a function of depth should be determined.
8.22 Results of such characterisations will assist in the preparation of radiation and contamination maps. Some of these results and maps may be available from audits performed during the facility’s operational period. However, such surveys may need to be updated to account for radiological decay and the in-growth of daughter products.
8.23 Radiological characterisation data should include zone description (e.g. facility, environment ground and surface water, soil, and sediments), contamination and dose rate levels, chemical and physical forms of materials. Characterisation surveys should also identify adjacent uncontaminated zones. During decommissioning activities special attention should be given to prevent cross contamination of such zones. Radiological characterisation of the facility should describe contamination and activation levels.
8.24 The radioactive waste inventory including waste that has both radionuclides and hazardous constituents should be also performed by type, waste description, processing status, location and radiological and hazardous materials conditions.
8.25 The following are special cases where care should be taken during characterisation:
fissile material inventories where criticality events may occur since uncertainty about the amounts or presence of fissile material could have severe consequences if assessments for criticality are incomplete or wrong;
with liquid or gaseous effluents or ponds which were utilized for storage or evaporation;
where unplanned cessation of operation occurred;
where failures of spent fuel elements occurred;
where waste was buried;
where previous decontamination/remediation occurred and facilities are reused; and
where underground or buried piping and liquid storage and drain collection systems existed.
8.26 Information and data obtained during the characterisation process should be incorporated in the final decommissioning plan as appropriate.
Non-radiological characterisation
8.27 Non-radiological hazards should be considered and evaluated during planning with regard to their potential impact on methods, processes and tasks for undertaking decommissioning and in particular on radiological protection of operators, the public and the environment.
Soil and sediment & surface and groundwater remediation
8.28 During operations, the contamination of surface and subsurface soil, sediment, and ground and possibly surface waters, may occur and should be characterised and evaluated. Contamination may result from effluents; leakage from buildings, piping and liquid storage systems; incidents; leaching through evaporation ponds; and waste burial. Additional to the facility, characterisation and remediation may be needed onsite and offsite if radioactive material has migrated in surface or groundwater.
8.29 Remediation of these modes may be required in order to meet the endpoint goal of restricted or unrestricted release of the facility and may involve treatment of soil, sediment or liquids that are contaminated with both radiological and non-radiological hazardous chemicals. Remediation actions may involve physical or chemical techniques necessary to remove the radiological contamination from the groundwater system, for example, pumping and chemical treatment or volatilisation processes.
8.30 If permitted by ARPANSA, remediation actions may be taken prior to the approval of the decommissioning plan. An example of when such remediation actions might be taken would be when concentrated areas of contamination are known.
8.31 Guidance on the remediation process can be found in the IAEA Safety Standards Series publications [19].
Evaluation of infrastructure
8.32 The various SSCs and buildings should be evaluated for their suitability, condition and fitness for decommissioning and for ensuring safety during decommissioning based on the results of the safety assessment. The evaluation should be used for final decommissioning planning. The level and extent of facility evaluation depends on, for example:
the proposed use, safety functions or requirements of the SSCs during decommissioning;
condition of the SSCs;
modifications needed for decommissioning e.g. additional floor and crane loading capability;
extent of inspection and maintenance of SSCs; and
end state of decommissioning e.g. reuse of building or structures versus demolition.
8.33 Assessment areas which should be covered include:
evaluation of building structures and cranes for stability and loading capability;
evaluation of structural integrity of the SSCs;
availability and adequacy of systems supporting the SSCs e.g. alarm and communication systems, ventilation systems;
adequacy and integrity of infrastructure required for decommissioning e.g. electrical supply, effluent drainage and transfer systems, waste storage suitability and capacity;
processes and infrastructure interfaces with other facilities in the case of multi-facility sites; and
facility modification and decommissioning infrastructure.
8.34 Depending on the strategy to be implemented, infrastructure should be established and/or modified to facilitate immediate dismantling or in some cases to prepare the facility for a safe enclosure period.
8.35 For immediate dismantling the main modifications may involve:
modification or substitution of SSCs that are important for ensuring safety during decommissioning, such as filtration and ventilation systems;
creation of buffer storage areas for equipment, materials and waste;
establishing new access and transport routes for personnel and equipment to, and within, the facility;
installation of additional equipment (e.g. handling and monitoring equipment); and
modification of existing waste processing equipment or establishing new equipment.
8.36 For deferred dismantling and safe enclosure the main modifications may involve:
establishing physical protection measures;
establishing passive containment systems; and
creating storage areas for equipment, materials and waste.
8.37 The management system in place during operation should be reviewed and revised to ensure that all equipment necessary for safety during decommissioning is monitored according to a defined schedule to maintain its safety function and to detect any degradation. Some of this equipment will be available from the operational period of the facility but it should be assessed both for suitability in the changing circumstances of decommissioning and for the extension of the period of its use.
8.38 As part of this exercise in reviewing the systems required for decommissioning, systems that are not required to support the decommissioning strategy should be identified. As long there is no impact on other facilities on a multi-facility site, surveillance and maintenance carried out on these systems can cease.
Decommissioning tasks
8.39 Decommissioning tasks that are typically conducted include decontamination, dismantling, demolition, clean-up and soil remediation in the vicinity of the facility. The objectives of these decommissioning tasks include:
reduction of potential onsite and offsite hazards during decommissioning activities;
reduction of exposure dose rates to permit manual or semi-remote dismantling and demolition;
reclassification of waste to less hazardous categories;
volume reduction of waste for disposal; and
salvage of equipment, materials or premises permitting unrestricted use of the item.
8.40 Supporting tasks that were conducted during facility operation and that will continue during decommissioning could include waste processing, storage and disposal; environmental monitoring; surveillance and maintenance of equipment and systems.
Surveillance and maintenance of structures, systems and components (SSCs)
8.41 Surveillance and maintenance of the SSCs designated as safety related for decommissioning, should be carried out from when operations cease until decommissioning is completed and during any period of deferred decommissioning.
8.42 If activities of decontamination and dismantling are deferred in part or in whole, safety should continue to be ensured through a proper surveillance and maintenance program. Under a deferred dismantling strategy, the surveillance and maintenance program might possibly be reduced during the period of deferral. If a facility is to be entombed a limited surveillance and maintenance program may still be necessary.
8.43 Before a facility is put into a period of deferral before dismantling the risk of potential incidents should be minimised. For example, spent fuel, bulk process radioactive material, and operational waste should be removed. Consideration should be given to removing, containing or immobilising any remaining loose contamination, where practicable. The following activities should continue to be performed and records of such activities will be kept:
maintenance of appropriate systems for physical protection commensurate with the risk entailed;
monitoring, surveillance and inspection, commensurate with the level of hazard;
maintenance of essential equipment, such as equipment for ventilation, mechanical handling and monitoring;
maintenance of the facility and the barriers and/or containment structure; and
maintenance of records about the surveillance and maintenance activities performed.
Selection and implementation of decommissioning techniques
8.44 Decommissioning tasks typically include decontamination, dismantlement, and demolition. Many techniques have been developed that may be applicable to decommissioning. Suitable decommissioning techniques should be established as part of decommissioning planning and their applicability to the particular decommissioning tasks thoroughly evaluated before selection. Site or facility specific features may require particular techniques to be developed but the objective should be to select proven techniques that are commercially available. International exchanges of information and experience should be encouraged.
8.45 New decommissioning techniques should be justified and demonstrated as capable of obtaining the desired outcome from both a performance and safety perspective. In this case benefits can be taken from computer-based as well as physical mock-ups to select decommissioning techniques, to evaluate options, to aid in the design and to train personnel. Innovative techniques should be verified in mock-up trials and other simulations prior to their use in decommissioning.
8.46 Systems, processes and components to which little attention has been given during operation or for which access is limited may have resulted in system degradation. Such systems present special consideration when decommissioning techniques are considered. Examples include liquid storage tanks and remote handling systems. Some possible problems associated with liquid storage tanks include difficulty in accessing, characterising, retrieving sludge and tank clean-up.
8.47 Before any decommissioning technique is selected an evaluation of its suitability should be conducted. The following factors may influence the suitability of the decommissioning techniques:
cost–benefit analysis comparing the radiological benefits and waste management benefits of the decommissioning technique with the expected costs;
potential impact on the workers and the environment for example giving preference to techniques that do not generate airborne radioactivity;
types and properties (e.g. size, shape, contamination limits and accessibility) of the equipment and structures to be dismantled;
decontamination factor and cutting rate likely to be achieved;
compatibility of existing SSCs with decontamination solutions and processes to ensure they will not be degraded and become ineffective;
impact on adjacent systems and structures and on other work in progress;
methods available for controlling radiological and non-radiological hazardous materials;
reliability of the dismantling equipment and tools and their simplicity to operate, decontaminate and maintain;
availability of waste containers and the associated handling systems and routes for disposal; and
time and schedule constraints.
8.48 Similar to the selection of decommissioning techniques, supporting tasks (including waste and materials management, storage and disposal; environmental monitoring; surveillance and maintenance of equipment and systems), should be continued from operation or implemented for decommissioning. These tasks should be thoroughly assessed before selection.
Decontamination and clean-up
8.49 Decontamination covers the broad range of activities directed to the removal or reduction of radioactive contamination in or on materials, structures and equipment at a facility. Decontamination is usually performed using decontamination agents (e.g. liquid solutions, foam, gel, etc.) or physical removal of contaminated surfaces and components.
8.50 Decommissioning of a facility may be aided at certain stages by partial or total decontamination. Decontamination may be applied to internal or external surfaces of components and systems, structural surfaces and the tools employed in decommissioning. The process of decontamination can be conducted before, during or after dismantling.
8.51 The main objectives of decontamination include:
reducing exposures during decommissioning activities;
minimising the volume of waste and the categories of material to be classified or disposed of as solid radioactive waste; and
increasing the opportunities for recycle and reuse of equipment, materials or premises.
8.52 Before any decontamination technique is selected an evaluation of its effectiveness and of the potential for reducing total exposure should be performed. SSCs should be assessed for compatibility with techniques, processes and agents that may be used during decontamination to ensure that their effectiveness will not be degraded during decontamination. The evaluation should include:
probable radiation doses involved;
decontamination factor likely to be achieved;
cost–benefit analysis comparing the radiological benefits and waste management benefits of the decontamination effort with the expected costs;
potential impact on the workers and the environment; and
assessments of the primary and secondary wastes arising from the decontamination, including their treatment volumes, physical and chemical forms, and activity.
8.53 Consideration should be given to the compatibility of wastes generated during decontamination with existing systems for the handling, treatment, conditioning and disposal of wastes. Before waste is generated, adequate arrangements for its handling and management should be in place.
8.54 After dismantling of the process and supporting equipment clean-up of buildings may be necessary. A methodology must be developed and implemented to remove the contamination using appropriate processes and tools depending on the type of construction and objectives to be achieved. Clean-up of buildings may involve specific techniques to remove a surface or concrete layer by grinding or scarifying using pneumatic hammers or other industrial demolition equipment.
Dismantling
8.55 There are many options available for dismantling, and their selection depends on the types and characteristics (e.g. contamination, activation, size, shape and accessibility) of the SSCs to be dismantled. Further information on these technologies as well as their advantages and disadvantages can be found in IAEA and OECD NEA publications [20].
8.56 Careful selection and pre-testing of the dismantling technology and procedures assists in minimising the decommissioning time, the volume of radioactive wastes and the dispersion of contamination; the optimisation of radiation exposure doses; and contributes to safety. Each dismantling task should be analysed to determine the most effective and safe method to perform it.
8.57 Dismantling may be aided at certain stages through the reduction in the need for radiological controls by means of the partial or total decontamination of the SSCs to be dismantled.
8.58 Dismantling activities by themselves may spread contamination. Cutting and demolishing (such as by abrasion or explosives) can result in the dispersion of radioactive dust. Consideration should be given to techniques to minimise the production of airborne radioactive material and implementing effective methods of its control such as using water sprays, controlling airflow and using filtration. Care should be exercised during demolition to ensure that contaminated material is segregated from non-contaminated material and non-radiological hazardous materials.
8.59 There are many techniques and methods available for dismantling (e.g. in atmosphere or underwater cutting, remote or not, etc). Special tools and devices may be required during the dismantling activities. These tools and devices together with the techniques for their operation and maintenance should be tested in simulated conditions before their use. Maintenance and periodic testing of these tools and devices should be included in the design and deployment strategy for them.
8.60 The applicant may consider the following:
reliability of the dismantling equipment and its simplicity to operate, decontaminate and maintain;
effects of dismantling task on adjacent systems and structures and on other work in progress;
effective methods available for controlling airborne radionuclides and generated wastes;
training requirements;
designated waste management routes; and
time required for dismantling.
8.61 Computer-based as well as physical mock-ups may be used to plan dismantling tasks, to evaluate options, to aid in the design of tooling and to train personnel.
8.62 Depending on the decommissioning end state demolition of the building structure may be required. In many cases, activities for decontamination and dismantling are aimed at making the demolition of the building structure a non-radiological activity. Where demolition of structures involves radioactively contaminated material, the safety considerations set out previously for decommissioning activities should be applied.
Waste and materials management
Requirement 14: Radioactive Waste Management
The licence holder and/or responsible person must establish methods to safely manage all radioactive waste streams.
8.63 The aim of radioactive waste management is to effectively isolate the waste during the time when it has the potential to give unacceptably high radiation doses to people or to the environment.
8.64 Decommissioning invariably involves the generation of large amounts of radioactive wastes. In the course of decommissioning waste will be generated in forms that may be different from materials and wastes of the types routinely handled during the operational phase of a facility. Appropriate techniques for decontamination and dismantling should be applied and the volumes of wastes generated should be minimised. Systems and facilities must be available for managing the waste generated during decommissioning including storage and/or disposal facilities. It may be necessary to temporarily store dismantled material and/or radioactive waste during active decommissioning.
8.65 Materials should be reused or recycled to the extent practicable to minimise the amount of radioactive waste to be managed. Some waste may be suitable for disposal in normal land-fill sites while some materials such as steel and concrete may be suitable for recycling or reuse outside the nuclear industry.
8.66 Part of the materials and waste arising during the decommissioning process may be sufficiently low in activity concentration for regulatory control to be wholly or partly removed. Clearance, which is the removal of radioactive materials or radioactive objects within authorised practices from any further regulatory control, may be granted by ARPANSA for the release of material from the site [21].
8.67 Planning and execution of decommissioning should ensure that the volumes of resulting wastes fall into the lowest possible categories of radioactive or hazardous waste streams. That is, planning and decommissioning methods don’t result in lower category waste unnecessarily being included in higher category streams, e.g. when demolishing reactor vessels or shielding.
8.68 The removal of regulatory controls will only occur after the licence holder and/or responsible person has demonstrated compliance with the criteria established by ARPANSA. The waste management plan should identify the manner for segregating radiological, non-radiological and hazardous wastes and the manner in which material will be cleared and released from the site.
8.69 Clearance and removal of radioactive materials and objects from regulatory control is discussed further in Appendix III.
Waste Management Plan
8.70 Radioactive Waste Management Plan must be submitted as part of plans and arrangements for managing safety. Regulatory Guide: Plans and Arrangements for Managing Safety describe the regulatory expectations for waste management [14].
8.71 The waste management plan as a part of the decommissioning plan should cover all anticipated waste and material categories. The plan could be based on the waste management plan for the operating facility with provisions for additional waste volumes and categories associated to decommissioning activities. Some of the waste categories may require new disposal end points. The plan should anticipate periods requiring the processing of high volumes of wastes and how to minimise any impacts on decommissioning activities or the operations of existing facilities at a multi-facility site or to optimise the waste management on such a site.
8.72 In managing the waste from decommissioning, several factors should be considered in the waste management plan including:
origin, amount, category and nature of the waste that will be generated;
minimisation of the waste;
the disposal route for radioactive wastes and availability of (interim) storage and disposal facilities;
free release of the dismantled material as appropriate;
reuse of equipment, premises and recycling of materials;
generation of secondary waste and its minimization;
mixed waste and the presence of non-radiological hazardous materials, such as beryllium and asbestos;
methods for treatment, conditioning, transport, storage and disposal;
availability of treatment capacities;
special transport and packaging requirements e.g. for activated components dismantling;
tracking systems for the radioactive waste;
traceability;
compliance to the waste acceptance requirements for processing facilities and storage (e.g. fissile material content); and
compliance to the waste acceptance criteria of disposal facilities.
Authorised discharges and environmental monitoring
8.73 During decommissioning radioactive and non-radioactive effluent may be generated. Discharges of material to the environment must be authorised by the relevant Commonwealth and State regulatory bodies and appropriately monitored by the licence holder and/or responsible person.
8.74 The regulatory authorisation and control of radioactive discharges to the atmospheric and aquatic environments is an aspect of radioactive materials management for operating nuclear reactors and radioisotope production facilities. Authorised discharges are also an aspect of radioactive materials management in the decommissioning phase.
8.75 Typically, controlled discharges of gaseous and particulate material containing radionuclides are made through stacks and controlled liquid discharges are made via pipelines into sewerage systems or surface water bodies. In general, during decommissioning, the expected discharges of effluents should be less than during operation of the facility but may be different in form and radionuclide composition.
8.76 It is typical for effluent discharges to vary through different stages of decommissioning. For example, as decommissioning leads to a progressive removal of radiological hazards, decommissioning results in the progressive reduction of radioactive discharges. In some instances decommissioning activities might result in elevated discharges for a limited period. Hence, the discharge authorisation for decommissioning should be revised as appropriate. If the facility undergoing decommissioning is part of a site with other operating facilities then the discharge authorisations for the facility and the site should be reviewed and revised in light of decommissioning.
8.77 An important and essential element in the control of discharges is regular monitoring both at the source of the discharge and in the receiving environment to ensure protection of the public and the environment. Monitoring of discharge points such as stacks and pipes is an example of source monitoring.
8.78 Environmental monitoring provides information needed for the assessment of the radiation doses to critical groups of the population from the presence of radioactive material or radiation fields in the environment. Hence, unless an exemption is granted, the licence holder and/or responsible person should establish and implement a program for monitoring the environment in the vicinity of the decommissioning site both onsite and offsite to assess the radiological impacts of radioactive releases on the environment. Guidance for developing and implementing an environmental monitoring program can be found in the IAEA Safety Standards Series publications [22].
8.79 Discharge authorisation requires discharge and environmental monitoring. Discharge points (such as stacks) used for effluent and environmental monitoring during the operational period may be used if sufficient in scope. If insufficient, appropriate substitutes should be made. Guidance for developing and implementing a source monitoring program and for setting discharge limits can be found in IAEA Safety Standards Series publications [23].
Physical protection and safeguards
8.80 Appropriate physical protection for the facility, commensurate with the associated threat level at the time needs to be maintained throughout decommissioning [2]. The security plans and arrangements requires submitting to ARPANSA with the final decommissioning plan for approval.
8.81 The objective of the security plans and arrangements is to prevent unauthorised access to the facility, sabotage, damage, theft, loss or unauthorised use. The arrangements should include administrative and physical controls and barriers to ensure that control is not relinquished or improperly transferred.
Guidance on ARPANSA’s expectations for security plans and arrangements can be found in Section 6 of Regulatory Guide: Plans and Arrangements for Managing Safety [14].
Emergency preparedness
Requirement 13: Emergency Planning
The licence holder and/or responsible person must establish and maintain emergency planning arrangements commensurate with the hazards and must report events significant to safety in accordance with regulatory requirements
8.83 An appropriate program for emergency planning must be established, described in the final decommissioning plan, and maintained throughout decommissioning. Such a program should be submitted to ARPANSA with the final decommissioning plan.
8.84 The licence holder and/or responsible person must develop plans and arrangements for implementation in accordance with the emergency program. The plan should be based on an assessment of the consequences of reasonably foreseeable accidents during decommissioning and should be aimed at minimising radiological consequences and ensuring protection of on-site personnel, the public and the environment.
8.85 The organisations with roles in the emergency plan should ensure that procedures are prepared for implementation in accordance with the plan. The organisations should be prepared for such emergencies and adequate facilities and equipment should be available and maintained. Personnel should be trained in emergency procedures and consideration should be made for regular testing and updating of these procedures by conducting exercises periodically.
8.86 Guidance for emergency preparedness and response can be found in IAEA Safety Standards Series publications [24]. ARPANSA’s expectations for emergency plans, procedures and preparedness can be found in Section 7 of Regulatory Guide: Plans and Arrangements for Managing Safety [14].
9. Completion of decommissioning and surrender of licence
Requirement 13: Completion of Decommissioning Actions and Termination of Authorisation
The licence holder and/or responsible person must demonstrate that on completion of decommissioning actions the end state criteria as defined in the final decommissioning plan and any additional regulatory requirements have been met.
9.1 Before completing decommissioning the licence holder and/or responsible person should address the matters that ARPANSA will consider when deciding whether to accept surrender of the facility licence and release the site for restricted or unrestricted use.
Final inspection and radiological survey
9.2 On completion of decontamination and dismantling activities a final radiological survey of the facility needs to be performed.
9.3 Results of the final radiological survey should be compared with results of an earlier (pre-decommissioning) baseline radiological characterisation survey to demonstrate that: the decommissioning objectives in the final decommissioning plan have been achieved; the facility is in a safe state; and the facility meets ARPANSA’s requirements and criteria for residual radioactivity allowing restricted or unrestricted release from regulatory control.
9.4 Design and implementation of the survey should be discussed with ARPANSA during the planning period for the survey. The licence holder and/or responsible person should develop procedures that describe the approach to conducting the survey and the activities for demonstrating compliance with the release requirements and criteria. These procedures should be submitted to ARPANSA for review and approval.
9.5 The survey data should be documented in a final radiological survey report and submitted to ARPANSA for review and approval. The results of the survey will be a major portion of final decommissioning reporting.
9.6 An example of the content of the final radiological survey report is provided in Appendix IV.
Documentation and record retention
9.7 After completion of all decommissioning activities, appropriate decommissioning reporting documents should be prepared to record in a comprehensive way what has been done during decommissioning and to demonstrate that the end state for the site or facility (in the approved final decommissioning plan) has been achieved. This documentation should be retained in the form and for the time period agreed with ARPANSA.
9.8 Appendix V provides an example of final decommissioning reporting documents. The key final decommissioning reporting documents that should be retained for future use are the (updated) final decommissioning plan and the final radiological survey report.
9.9 A final decommissioning report should summarise decommissioning undertaken; dismantling of the facility; waste management including clearance of radioactive materials or objects from regulatory control; the final status of the site at the time for release from regulatory control or for conversion to other (nuclear) use; and any remaining restrictions on the site. The final decommissioning documentation should show as far as practicable that all radioactive materials present at the beginning of decommissioning are accounted for and their ultimate destination is confirmed.
Licence amendment or surrender and future site re-use
9.10 At a single facility site, the facility can be released from regulatory control after approval by ARPANSA. For a multi-facility site, the facility can be released from regulatory control or incorporated into another licensed facility.
Control of the facility released with restrictions
9.11 Release of the site or facility from regulatory control may be achieved progressively over parts of the facility or site or with restrictions to ensure radiological protection of human health and the environment. To achieve compliance with the appropriate release criteria, restrictions may be necessary for the use of or access to parts of the facility or site.
9.12 Specific restrictions should be established as necessary to control the removal of material from the site or facility, if that material cannot be released from regulatory control; the potential uses of a site or facility; and potential radiation exposure pathways. Appropriate arrangements for continuing control including financial assurances must be in place and the responsibility for their development, implementation and maintenance must be assigned unambiguously to a legal organisation or institution. Arrangements for the controls and monitoring compliance with them must be in accordance with regulatory requirements and approved by ARPANSA.
9.13 A plan for ongoing control, maintenance and surveillance of any area released with restrictions should be prepared by the licence holder and/or responsible person and approved by ARPANSA. Legal and financial arrangements should be made for implementation of the plan.
9.14 Interested parties should be informed of any restrictions on the site or facility and of the results of monitoring and surveillance.
9.15 For surrendering a facility licence and applying for release from regulatory control the applicant should refer to Regulatory Guide: Surrender of Facility Licence and Release from Regulatory Control [21]
[13] International Atomic Energy Agency, Regulations for the Safe Transport of Radioactive Material, 2012 Edition, IAEA Safety Standards Series No. SSR-6, IAEA, Vienna (2012).
[20] European Commission (EC), Co-ordination Network on Decommissioning of Nuclear Installations (CND), Dismantling Techniques, Decontamination Techniques, Dissemination of Best Practice, Experience and Know-how, 2009.
[23] International Atomic Energy Agency, Environmental Source Monitoring for Purposes of Radiation Protection, IAEA Safety Standards Series No. RS-G- 1.8, IAEA, Vienna (2005).
[24] International Atomic Energy Agency, Arrangements for Preparedness for a Nuclear or Radiological Emergency, IAEA Safety Standard Series No. GS-G-2.1, IAEA, Vienna (2007).
Appendix I
Factors influencing selection of a decommissioning strategy
To assist the development of decommissioning strategies, some of the factors affecting the selection of a decommissioning strategy are further described below.
Optimisation of radiological protection of workers, the public and the environment
A1. An important principle in selecting the decommissioning strategy is to ensure that the level of radiation protection for each source of radiation is optimised so that individual doses and collective doses are kept as low as reasonably achievable, economic and social factors being taken into account (ALARA). Radiation protection is considered to be optimised when the level of protection needed to further decrease individual or collective doses cannot be achieved without an unreasonable social or economic cost. This includes exposure of the public and the environment that might result from radioactive discharges via airborne and liquid effluents during decommissioning.
A2. In selecting a strategy to optimise radiation dose to occupational personnel, the public and environment, consideration should be given to:
residual radiation at the commencement of decommissioning;
timing of the start of decommissioning and the schedule and sequence in which decommissioning is carried out;
available decommissioning technologies, techniques, expertise and services;
the use of remote handling and tooling technology for large nuclear installations such as reactors and radioisotope production facilities;
decontamination of structures, systems and components if necessary before decommissioning starts;
the time that occupational personnel would need to spend in radiation zones. Training with inactive mock-ups and models may improve efficiency;
the availability of and access to radiation protection services and equipment;
the need for fixed or portable shielding between the radiation source and the occupational personnel; and
the availability of waste handling and storage facilities and services to avoid undue accumulation of waste and the spread of contamination by clearing away waste as it is produced.
Compliance with the legal framework
A3 Decommissioning of a nuclear installation may only be undertaken in accordance with the regulatory framework. This framework should be considered when selecting a strategy and planning for decommissioning.
Type of nuclear installation, interdependencies with other facilities or infrastructure located at the same site
A4. The type of controlled facility (e.g. nuclear research reactor, radioisotope production facility or research facility), its past functions, operational history and the extent of clean-up needed (e.g. soil/sediment and surface and groundwater) will have major impacts on the strategy selected.
A5. These facilities can be categorised by residual radionuclides according to the operations that were performed, the size and location of the facility and its relationship with other facilities on the site. The specific characteristics of each facility will strongly influence the selection of the decommissioning strategy.
A6. Furthermore, in selecting a strategy consideration should be given to non-safety related matters such as reuse or recycling of materials as opposed to disposal. Where relevant, safeguards related issues should also be considered in optimising both safety and resources in the decision-making process for the optimal decommissioning strategy.
A7. The extent of contamination in a facility will depend greatly on past operational practices, the age and type of facility. The period of design and construction will have influenced the types of materials used in construction which in turn affects the level and type of residual radioactivity in the facility. The design of the facility particularly whether decommissioning was considered in its design will affect the ease of decommissioning and choice of strategy.
A8. Account should be taken of the characteristics of the site where the facility is located. At a multi-facility site, the capabilities of and synergies with other facilities on the site may lead to better safety approaches for decommissioning although the decommissioning of a facility should not be allowed to adversely affect safety of the other facilities. The capabilities of the other infrastructure and facilities (such as transport, handling, treatment and storage of radioactive waste) may be used as well as the capabilities and experience of the site’s personnel. These considerations may affect the options available for selection of a strategy.
A9. Additionally, the facility’s location within a multi-facility site may pose unique challenges to decommissioning. For example, a research reactor could be located in a research establishment or a radioisotope production facility might be located in a hospital. As a consequence it may be beneficial for example to place the oldest facilities into a deferred dismantling state until the remaining facilities are closer to permanent shutdown.
Proposed reuse and desired end state
A10. Alternatively, the potential demand for reuse of the site either for restricted or unrestricted use is an important consideration for the selection of a decommissioning strategy. The desired end state could be release from ARPANSA control, allowing new use of the all or part of the site or existing building structures. This might lead to a preference for selecting a strategy of immediate or early dismantling of part or all of the facility and/or decontamination of the existing building structure to a level suitable for new use.
A11. Reuse of the site is generally not compatible with entombment of a facility.
Physical status of the facility
A12. The integrity and conditions of the buildings and SSCs should be considered when selecting a decommissioning strategy. The length of time and work necessary to maintain and secure buildings and SSCs in order to preserve safe enclosure will influence the choice of decommissioning strategy and timing.
Facility radiological condition
A13. The types of radionuclides used at a facility can have a major impact on the exposure that workers, public and environment may receive during the decontamination and dismantling activities. Facilities that contain different levels of activity and contamination may pose different levels of risk of radiation exposure to workers, the public and the environment.
Availability of expertise, technologies and infrastructure
A14. The availability and use of institutional knowledge such as documentation of the operational history and/or retention and use of key personnel familiar with site-specific conditions should be considered in choosing a decommissioning strategy. Such documentation could assist in planning and undertaking decommissioning and may help to reduce problems associated with loss of corporate memory. A good system of recordkeeping for this purpose should be in place.
A15. Similarly, although the decommissioning process and the former operating phase require different human skills, staff with knowledge of the operation, maintenance, repairs, modifications and history of the operating facility would be useful for planning and undertaking decommissioning and help with knowledge transfer. This could also decrease the potential for events such as industrial accidents or undue exposures.
A16. An immediate dismantling strategy allows for direct use of operating personnel in dismantling activities. A consequence of selecting a deferred dismantling strategy would be that the personnel staff conducting final dismantling may have to be newly trained or experienced contractors engaged.
A17. In the case of a multi-facility site or facilities on various sites it could be useful to take advantage of the learning experience gained from decommissioning of the first facility by re-deploying experienced personnel or using the capabilities and personnel of one facility for decommissioning another. Benefits could be also realised by sharing decommissioning infrastructure, equipment and tools between facilities.
A18. Movement of workforce and equipment from one decommissioning project to the next may permit more effective decommissioning and a more efficient use of personnel and equipment and are factors for consideration in deciding the preferred decommissioning strategy.
A19. The techniques needed for dismantling activated and contaminated facilities are common to all decommissioning strategies. Although there will be differences in the application of dismantling techniques used for immediate and deferred dismantling strategies, the techniques chosen will be the same in principle. There are few advantages to be gained from waiting for technology to progress because most of the techniques needed already exist and are adequate. Remote dismantling techniques are less likely to be required after a period of safe enclosure.
Environmental and socioeconomic impact
A20. Because of the potential for deterioration of the facility or SSCs over time, the deferred dismantling strategy might result in the need for refurbishment or replacement investment and work being made before beginning the dismantling work. Deferred dismantlement requires a commitment to the prevention of environmental contamination by control during the safe enclosure period and by adequate building management and inspection. A strategy of immediate dismantling strategy may pose a lower risk of environmental contamination due to building deterioration.
A21. When the impact on the local economy is an important issue, immediate dismantling might be the preferred strategy because this will reduce the negative social effect while continuing to stimulate the local economy and provide employment for the local workforce.
A22. For most facilities, the number of employees and local support needed during decommissioning will generally be less than the number employed and local support during facility operations. If deferred dismantling is selected as the strategy, the workforce will be reduced considerably during the enclosure period and then may increase again during later dismantling.
Waste management
A23. Aspects of waste generation and waste management can have an impact on the selection of a decommissioning strategy. Some of the most important aspects are:
overall national waste management strategy (e.g. one that prefers clearance);
types, categories and amount of waste arising during decommissioning;
availability of waste treatment facilities or infrastructure for all types of radioactive waste;
infrastructure for the transport of radioactive materials;
availability of storage capacity; and
availability of final disposal capacity.
A24. In the absence of waste treatment facilities or infrastructure, interim storage capacities or disposal capacity, the preferred strategy decommissioning is likely to be deferred dismantling. In the case of no existing disposal capacity but external or on-site waste treatment and storage facilities, immediate dismantling is a viable decommissioning strategy. If disposal capacity is available then both immediate dismantling and deferred dismantling are viable strategies.
Appendix II
General content of a final decommissioning plan
The following list of elements of decommissioning plans has been developed based on several reference publications [1-3]. Some of these elements such as safety assessment and environmental impact assessment are usually incorporated into the decommissioning plan by reference and a short summary provided in the decommissioning plan. Following a graded approach, the level of detail will depend on the complexity of the decommissioning activity.
1. Introduction
2. Facility description
2.1. Site location and description of the site and facility
2.2. Building, systems and equipment description
2.3. Facility and site radiological characterizations and surveys
2.4. Site and facility operational history and historical developments including site releases, incidents and corrective actions
3. Decommissioning strategy
3.1. Objectives
3.2. Decommissioning strategies
3.3. Selection and justification of preferred strategy
4. Decommissioning management
4.1. Management system
4.2. Safety management
4.3. Organizational and administrative controls
4.4. Staffing, qualification and training
4.5. Project management
4.6. Quality management
4.7. Documentation and recordkeeping
4.8. Contractors involvement
4.9. Decommissioning schedule
4.10. Specific decommissioning issues such as coordination with multiple competent authorities, stakeholder involvement
5. Conduct of decommissioning
5.1. Contaminated structures, systems and equipment
5.2. Surface and subsurface soil and sediment
5.3. Ground and surface water
5.4. Decontamination and dismantling techniques and technologies
5.5. Decommissioning release criteria
5.6. Surveillance and maintenance
6. Waste management program
6.1. Identification of waste streams
6.2. Solid radioactive waste
6.3. Liquid radioactive waste
6.4. Waste containing both radionuclides and other hazardous material
6.5. Clearance
7. Cost estimate
8. Radiation protection
9. Safety assessment
9.1. Identification of hazards and initiating events
9.2. Evaluation of occupational and public exposure during decommissioning
9.3. Evaluation of potential exposure
10. Environmental impact assessment
11. Emergency planning
12. Physical protection and safeguards
13. Final radiological survey design
13.1. Map or drawing of the area to be surveyed
13.2. Sampling parameters
13.3. Background/baseline levels
13.4. Types of equipment, instruments, techniques and procedures
13.5. Methodology for evaluating survey results
13.6. Demonstration of compliance with the release criteria
13.7. Ongoing restrictions arising
13.8. Records to be maintained
14. Summary
References
[II-1] International Atomic Energy Agency, Decommissioning of Nuclear Facilities, IAEA Draft Safety Guide DS452, IAEA, Vienna (2017).
Exemptions, clearance, removal from regulatory control and surrender of a facility licence
This appendix provides guidance to assist the determination of whether ARPANSA will accept exemption or clearance of radioactive material or radioactive objects from regulatory control during decommissioning; or release a facility from regulatory control, following decommissioning, and surrender of a facility licence. A licence holder and/or responsible person seeking such approvals needs to ensure the principles included in this appendix are covered in their submission to ARPANSA.
Regulatory control is any form of control or regulation applied to nuclear installations and radiation activities by ARPANSA for reasons related to nuclear safety, radiation protection or nuclear security [1]. Regulatory control is generally exercised through facility or source licences.
Exemption is determination by ARPANSA that radioactive materials or radioactive objects, or radiation activity, need not be subject to all or some aspects of regulatory control [1].
Clearance is the removal of radioactive materials or radioactive objects within authorised (licensed) facility or activity from any further regulatory control [1, 2].
While exemption is used as part of a process to determine the nature and extent of application of the system of regulatory control, clearance is intended to establish which material under regulatory control can be removed from this control. As with exemption, a clearance may be granted by ARPANSA for the release of material from a facility or activity.
General Criteria
It is generally accepted that regulatory control is not warranted if the radiation risks arising from a radiation source or activity, cleared material, or decommissioned facility are sufficiently low.
Radiation risks are considered to be sufficiently low provided that under all foreseeable circumstances the effective dose expected to be incurred by any member of the public is in the order of 10 µSv or less per year. For low probability scenarios, the effective dose should not exceed 1 mSv [1]. In regard to international best practice (IBP) some regulatory bodies use 10 µSv/yr as equating to sufficiently low risk.
Values of Activity and Concentration for Exemption and Clearance
Various scenarios of foreseeable circumstances have been analysed to determine maximum values of activity and concentration of radionuclides that are consistent with these criteria [3].
Activity and concentration limits for the exemption of moderate amounts of materials (up to one tonne) and mixtures of materials are given in Schedule 1 Part 1 of the Regulations [4]. For the exemption and clearance of bulk amounts of materials, concentration limits are given in Schedule I Table I-1 of IAEA GSR Part 3 [1].
IAEA advice on the application of exemption principles is provided in IAEA RS-G-1.7 [2].
Naturally occurring radionuclides are excluded using the descriptions of exempt dealings in Schedule 1 Part 1 of the Regulations [4] and the Natural Origin Exemption Levels where 40K is 10 Bq/g and 1 Bq/g is used for all other radionuclides of natural origin. For noble gases, the exemption levels should be those provided in Part 1 of the Regulations. For a mixture of both natural and artificial origin nuclides, both of the conditions for mixtures apply.
Release of a controlled facility from regulatory control
Surrender of a facility licence and release from regulatory control is discussed in references [5] and [6]. The guiding principles for release of a controlled facility from regulatory control are:
a) The remaining structures, systems components and the environment at the location of the facility must no longer contain any radioactive material unless the material(s) are exempt from regulatory control.
b) All materials containing non-exempt radionuclides must be transferred to an appropriate licence or disposed of using an approved method.
c) The risk from radioactivity levels at the facility location which are associated with the facility (i.e. above natural background) needs to be sufficiently low.
ARPANSA must be satisfied that the licence holder and/or responsible person has adequately demonstrated by analysis or measurement or both that radionuclide total activities or concentrations are below the exemption levels. Consideration should be given to commissioning independent assessment or measurement.
Before a licence may be surrendered the operating organisation must account for the full inventory of non-exempt radioactive material arising from the decommissioning process and its transfer or disposal. Additionally, the licence holder and/or responsible person must demonstrate that all non-exempt waste is managed appropriately. Regulatory guidance on the disposal of radioactive material is given in reference [7].
ARPANSA must be satisfied that risks from any residual radioactivity levels resulting from the decommissioned facility are sufficiently low, taking account of any restrictions on its future use. An application to surrender a licence must demonstrate that the dose expected to be incurred by any member of the public is in the order of 10 µSv per year or less. Justification should be provided by the operating organisation to deviate from this objective.
References
[III-1] European Commission, Food And Agriculture Organization Of The United Nations, International Atomic Energy Agency, International Labour Organization, OECD Nuclear Energy Agency, Pan American Health Organization, United Nations Environment Programme, World Health Organization, Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards, IAEA Safety Standards Series No. GSR Part 3, IAEA, Vienna (2014).
[III-6] Australian Radiation Protection and Nuclear Safety Agency: Regulatory Guide: Surrender of a Facility Licence and Release from Regulatory Control (2014).
The final radiological survey report presents the final conditions at the facility and site at the conclusion of the physical decommissioning activities. The report is a part of the final decommissioning reporting documentation and includes:
Final Radiological Survey Plan containing:
Location of the facility
Type of facility
Site and facility description such as: site; facilities; buildings; any remaining subsurface structures included in the final survey; and facilities remaining in operations and their interdependencies
Survey design justification based on:
Initial site radiological characterization including background levels
Initial facility radiological characterization, including any additional characterisation needed
Identification of potential sources or areas of contamination
Locations including significant ratios between radionuclides (radiological characterization)
Survey areas including their radiation classification
Survey design details including:
Types of surveys to be conducted
Type of instrumentation to be used, their sensitivity and techniques for use
Sampling plan (e.g., map, type and number of measurements and analyses to be performed)
Procedures for recording measured data and analytical results
Procedures for evaluation of data and results, comparison with established guidelines, and reporting consistent with regulatory framework
Quality assurance for radiological survey procedures
Conduct of Survey and Survey Results
Summary of survey including changes from the Final Radiological Survey Plan
Sampling performed (e.g., map, type and number of measurements and analyses performed)
Measured data and analytical results
Data evaluation, comparison with previous radiological surveys and established guidelines and release criteria, and reporting consistent with regulatory framework
Quality assurance for survey results
Summary and Conclusion
Concise description of the final radiological situation at the facility including any areas that were not surveyed
Identification of all areas, systems and components that can be released for unrestricted use
Identification of all areas, systems and components that can be released with restrictions
Description of any institutional controls that will be required for areas that can not be released, including overview drawings and maps
These final decommissioning reporting documents could include:
Final decommissioning plan, updates and any related authorisations
(including decommissioning safety assessments and decommissioning environmental impact assessments and their updates)
Final radiological survey report
(for facilities and site leading to release with restricted use, list of designated structures, areas and equipment and description of restrictions and eventual removal of controls, if applicable)
(c) a person in the capacity of an employee of a Commonwealth contractor
(d) a person in a prescribed Commonwealth place
[2] controlled facility means: (a) a nuclear installation; or (b) a prescribed radiation facility; or (c) a prescribed legacy site.
[3] A Responsible Person has the same meaning as a Person Conducting a Business or Undertaking (PCBU), as defined in the Commonwealth Work Health and Safety Act 2011, who is conducting a business or undertaking that uses radiation and requires authorisation under appropriate legislation.
Responsible person is defined in the Code for Radiation Protection in Planned Exposure Situations Radiation Protection Series C-1
[4] IAEA safety standards give guidance for each situation ([1] and [9])
This regulatory guide is designed to assist a controlled person when applying for a facility licence under section 32 of the Australian Radiation Protection and Nuclear Safety Act 1998.
This regulatory guide provides information for controlled persons (referred to as ‘the applicant’ in this guide) applying for a licence for a radioactive waste storage or disposal facility and associated ancillary facilities under the Australian Radiation Protection and Nuclear Safety Act 1998 (the Act) and the Australian Radiation Protection and Nuclear Safety Regulations 2018 (the Regulations)1. It supersedes the regulatory guide Licensing of Radioactive Waste Storage and Disposal Facilities (REG LA SUP 240L v2) issued in March 2013.
The guide addresses issues that should be considered when applying for a licence for a controlled facility designed to store large quantities of low and intermediate level radioactive waste including long term storage of such waste, noting that a storage facility may be operational for more than a century; or dispose of similarly large quantities of low level radioactive waste in a near-surface disposal facility. It is applicable to waste generated in activities carried out under a licence issued under the Act and only to waste generated in Australia, including waste generated during reprocessing overseas of spent nuclear fuel from nuclear reactors operated in Australia2.
The guide is not applicable to:
short-term storage of small quantities of waste
disposal of small quantities of low level waste at the point of generation3
management of waste generated during mining and milling of ores
waste facilities under state or territory jurisdiction.
The guide provides information on documentation, relevant to the type of facility and in line with a graded approach, to be submitted in order for the CEO of ARPANSA to make an informed assessment of whether the proposed facility sufficiently addresses the matters that should be taken into account by the CEO in making a licensing decision that is not in conflict with the object of the Act, which is to protect the health and safety of people, and to protect the environment, from the harmful effects of radiation. Failure to provide sufficient and satisfactory information may cause delays in the review of the application, or result in the application being declined.
1.2 General aspects of radioactive waste management
In Australia, radioactive waste is generated from a wide range of activities involving radiation sources, facilities and nuclear installations in the processing, use or generation of radioactive material in medicine, industry and research.
Effective and safe management of radioactive waste requires an appropriate classification of the waste. An internationally acknowledged scheme for classification of radioactive waste has been developed by the International Atomic Energy Agency (IAEA) in IAEA Safety Series GSG-1 Classification of Radioactive Waste (2009), which comprises six classes of radioactive waste. Australia has adopted this classification system through Radiation Protection Series RPS G-4 Guide for Classification of Radioactive Waste (2020).
The most important factor that determines the classification of the waste is the manner by which it can be safely disposed. This depends on the amounts and concentrations of radioactive substances, their properties including half-life (the time it takes for the activity to decay to half its original level), and other properties such as heat generation and chemical nature of the waste.
Radioactive waste storage and/or disposal facilities are components of a system for waste management that also includes transport routes from sites of waste generation or interim storage to the waste management facility. Additionally, radioactive waste from various activities may require predisposal management such as treatment and conditioning in ancillary facilities to ensure that it conforms to the waste acceptance criteria for processing, storage and emplacement into the disposal facility. Transport of waste to, from and between facilities must conform to requirements in the Transport Code RPS C-2 Code for the Safe Transport of Radioactive Material (2014).
Disposal refers to the emplacement of radioactive waste into a facility or a location with no intention of retrieving the waste. Disposal options are designed to contain and isolate the waste from the accessible biosphere by means of engineered and natural barriers in a manner that is commensurate with the hazard4.
Storage refers to the retention of radioactive waste in a facility or a location with the intention of retrieving the waste for conditioning (if needed) and ultimate disposal. The period of storage may vary depending on the waste and the type of facility. However storage is always an interim measure.
A storage facility may be located at a site where radioactive waste is generated; it may comprise a separate facility or it may be co-located with a disposal facility.
1.3 Structure of this guide and explanation of terms
Sections of this guide deal with the matters in section 53 of the Regulations that the CEO must take into account when deciding whether to issue a facility licence. The CEO will require an applicant to provide information to address those matters.
Section 46 of the Regulations lists the kinds of documents and information that the CEO may ask for in relation to an application. Depending on the activity to be authorised by the licence, the CEO will require whichever of those documents and information are relevant.
Matters in section 53 of the Regulations are listed below, with an indication as to where they are dealt with in this regulatory guide.
Matters specified in section 53 of the Regulations
Relevant section
(a) whether the application includes the information asked for by the CEO
Section 2: Information requested
(b) whether the information establishes that the proposed conduct can be carried out without undue risk to the health and safety of people, and to the environment
Section 3: Undue risk
(c) whether the applicant has shown that there is a net benefit from carrying out the conduct relating to the controlled facility
Section 4: Net benefit
(d) whether the applicant has shown that the magnitude of individual doses, the number of people exposed, and the likelihood that exposure will happen, are as low as reasonably achievable, having regard to economic and social factors
Section 5: Optimisation
(e) whether the applicant has shown a capacity for complying with these regulations and the licence conditions that would be imposed under section 35 of the Act
Section 6: Capacity to comply
(f) whether the application has been signed by an office holder of the applicant, or a person authorised by an office holder of the applicant
Appendix 2
(g) if the application is for a facility licence for a nuclear installation—the content of any submissions made by members of the public about the application
Not dealt with in this regulatory guide
Section 32(3) of the Act requires that in making a decision in relation to an application for a facility licence, the CEO must take into account international best practice in relation to radiation protection and nuclear safety. Information and documents that the CEO asks for in relation to a licence application will include information relevant to international best practice.
Additional information is provided in the appendices as follows:
Appendix 1 provides generic information on how to complete and lodge a licence application
Appendix 2 provides information on how a licensing decision is reached
Appendix 3 provides information on how an applicant can appeal against a decision.
Terms and their definitions in this guide are the same as in the Act and Regulations. To the extent terms that are used here are not found in the Act and Regulations, their use is aligned with the IAEA Safety Glossary 20075.
Use of the term ‘safety’ or the phrase ‘health and safety’ in this regulatory guide refers to radiation, waste, transport and nuclear safety, emergency management, and nuclear security, i.e., actions taken to achieve protection against radiation risks6. It does not refer to safety in the sense used in work health and safety legislation, or in other safety legislation.
Some concepts, principles and processes related to waste management are outlined in a supplementary document, Radioactive Waste Storage and Disposal Facilities: Information for Stakeholders. The information document can be read in conjunction with this regulatory guide as a source of explanations and background, but should not be considered a guide.
2. Information requested
Section 46 of the Regulations gives the CEO the power to ask an applicant for some or all of the information and documents mentioned in section 46 and other information about the application if appropriate.
This regulatory guide indicates the documents and information from Schedule 3 that the CEO will require as part of the application. This regulatory guide also indicates the documents and information that should be submitted by the applicant to enable the CEO to take into account the matters in section 46 of the Regulations as relevant to the type of facility and stage in the licensing process.
Use of ‘must’ in this guide indicates a mandatory legislative requirement. Use of ‘should’ statements indicates the CEO’s expectations in terms of what would be considered a complete application. A graded approach should be applied by the applicant to ensure that the depth and detail of information is appropriate to the nature of the facility and the activity to be authorised.
Under paragraph 53(b) of the Regulations, the CEO must assess whether the application includes all of the information asked for by the CEO, as relevant to the specific stage in the licensing process (see further Section 2.2).
A licensing decision will not be made unless and until the information provided by the applicant demonstrates that the proposed conduct can be carried out without undue risk to the health and safety of people and the environment. For facilities, this information will be collated in a safety case. The safety case is the collection of scientific, technical, administrative and managerial arguments and evidence in support of the safety of a facility, covering the suitability of the site and the design, construction and operation, the assessment of radiation risks, and assurance of the adequacy and quality of all of the safety related work that is associated with the facility.
Information provided in the safety case should support the applicant’s conclusions in relation to items (b) through (f) in section 53 of the Regulations (see Section 1.3) and will, where applicable, support consultation in relation to item (h).
2.1 The safety case
Objective: The applicant should prepare and maintain a safety case that allows for a full understanding of all aspects relevant to the safety of the controlled facility; it should contain references to supporting material. It should be in a form suitable to be used as the basis for consultation with all stakeholders on the safety of a facility for storage or disposal of radioactive waste as well as any ancillary facilities that may be part of the system for waste management7.
The safety case should outline all safety-related arguments the applicant draws on in support of the application. It should include information on the consultation activities undertaken by the applicant prior to seeking a licence and during development of the safety case and what conclusions have been drawn from such consultation.
A table outlining the information that the applicant should submit as part of the safety case is at Schedule 1, including references to relevant sections in this regulatory guide. The schedule contains the generic elements applicable to all stages in the licensing process, as well as specific elements that should be introduced at various stages in the licensing process. Note that the safety case is a living document; specific elements will continue to be relevant for subsequent licensing stages and need to be updated in the safety case.
A major component of the safety case is the safety assessment, which includes the safety analysis. Important elements of the safety assessment are radiological impact on humans and the environment, site and engineering aspects, operational safety, non-radiological impacts, and the management system. Safety should be achieved by applying the principles of defence in depth, optimisation, and, as relevant, through the use of best available technique8. The safety analysis is the evaluation of the potential hazards associated with a facility or activity, documented in a safety analysis report (SAR).
The safety case will be the main source of information for stakeholders during the consultation phase9. As such, the CEO will require a summary of the safety case in plain non-technical language, to facilitate communication and consultation.
The CEO will require information about compliance with other legislation relevant to the protection of health and safety of people and the environment such as the Environment Protection and Biodiversity Conservation Act 1999 (the EPBC Act) and the Nuclear Non-Proliferation (Safeguards) Act 1987. An application may be submitted to ARPANSA even if the environmental impact statement (EIS) or outcomes of the environmental assessment are not available. Assessment work by both agencies may continue in parallel but a licensing decision cannot be made by ARPANSA until the EIS and assessment of the EIS are provided.
As there is an obligation on the CEO to take international best practice into account in regulatory decision making, it is incumbent on the applicant to demonstrate how international best practice has been considered in the safety case. Information on international risk assessments and standards that are relevant in this context is available at the international best practice page. A licence application should also draw on relevant design concepts, operational experience, and decommissioning and closure experience from facilities in other countries with an advanced infrastructure for safety.
The safety case should acknowledge the existence of any unresolved issues and should provide information on work proposed to resolve these issues in future stages of the licensing process. Issues that have been resolved with ARPANSA and other stakeholders should be documented and form part of the safety case.
The safety assessment should also consider the safety implications of any proposed co-location of different types of radioactive waste management facilities. In the case of co-location, each facility would in most cases require a separate application and safety case, addressing the relevant requirements for each stage of facility development. The safety of transport to, from and between radioactive waste management facilities should also be considered noting that the responsibility for transport of waste to a storage or disposal facility lies with the waste owner. This may require prior approval of a transport safety and/or security plan by ARPANSA.
It is expected that the safety case will be updated for each stage of licensing or otherwise as required by the CEO of ARPANSA. For each stage, it should provide enough information about the subsequent licensing stages to allow for an informed decision on the feasibility of the storage and/or disposal concept, as well as of the system for radioactive waste management.
With each new licensing stage, the safety case will become increasingly informed by experience gained during previous stages and by safety and security reviews, if any such review has been performed. For a storage facility, the safety case should outline plans for the final management of the waste in storage, including its disposal.
The IAEA requirements for a safety case are outlined in:
The applicant is encouraged to implement a graded approach and direct efforts and resources to the matters that are most significant for protection of the health and safety of people, and of the environment.
2.2 Information specified in the Regulations
Subsection 46(2) of the Regulations outlines extra information that the CEO may ask for.
For a facility covered by this regulatory guide, the information below will be required by the CEO as part of the application and should form part of the safety case.
The schedule differentiates between the different stages of licensing; however, as stated earlier, an application should also go into some detail about subsequent licensing stages. That is, the level of detail of information required at the various stages of licensing will vary and should be proportionate to the particular stage. For example, an emergency management plan is not expected to be as detailed in the application to site a facility as in the application to operate the facility.
General information
The CEO will require the following information as part of the safety case before a licensing decision can be made
1(a)
The applicant’s full name, position and business address
1(b)
A description of the purpose of the facility that is to be authorised by the facility licence
1(c)
A detailed description of the controlled facility and the site for that facility
1(d)
Plans and arrangements describing how the applicant proposes to manage the controlled facility to ensure the health and safety of people and the protection of the environment
Note that further details relevant to 1(d) are outlined in Sections 3 and 5, and in Appendix 2, of this regulatory guide.
Prepare a site for a controlled facility
The CEO will require the following information as part of the safety case before a licensing decision can be made
1(a)
A detailed site evaluation establishing the suitability of the site
1(b)
The characteristics of the site, including the extent to which the site may be affected by natural and human events
1(c)
Any environmental impact statement (however described) requested or required by a Commonwealth State or Territory government agency in relation to the site or the facility, and the outcome of the environmental assessment10
The selection of a site for a controlled facility requires that the conceptual design has been established so that the suitability of the site can be adequately assessed in relation to the general safety features of the facility. The performance of the barriers (engineered and natural) that separate the e from the biosphere should be well understood and documented in the safety assessment and through the first iteration of a safety analysis report (preceding the preliminary safety analysis report required in the construction stage). The characteristics of the site as well as its evolution in terms of such things as geology, hydrology, biology, demography and land use should be well characterised.
Apart from a detailed site characterisation, all information may not be developed in full detail at the time the siting application is submitted and will be gradually refined as the safety case evolves. However, the application should provide sufficient information to demonstrate that the facility can provide protection of the health and safety of people and of the environment under all reasonably foreseeable circumstances at the time of application.
Construct a controlled facility
The CEO will require the following information as part of the safety case before a licensing decision can be made
2(a)
The design of the controlled facility, including ways in which the design deals with the physical and environmental characteristics of the site
2(b)
Any fundamental difficulties that will need to be resolved before any facility licence relating to the facility is issued
2(c)
The construction plan and schedule
2(d)
A preliminary safety analysis report that demonstrates the adequacy of the design of the facility and identifies structure, components and systems that are safety related items
2(f)
The arrangements for testing and commissioning safety-related items
The safety case for the construction phase should include a preliminary safety analysis report (PSAR) that takes into account the detailed design of the facility and demonstrates that the safety issues have been satisfactorily resolved. The safety case should demonstrate that construction will result in a facility that has the potential to be licensed to operate and be decommissioned or closed (as appropriate) while providing for the protection of health and safety of people and the environment.
Possess or Control
The CEO will require the following information as part of the safety case before a licensing decision can be made
3(a)
Arrangements for maintaining criticality safety during loading, moving or storing nuclear fuel and other fissile materials at the facility
3(b)
Arrangements for safe storage of controlled material and maintaining the facility
The safety case for the possess or control phase should detail arrangements for maintaining the facility in the event that such a licence is required before radioactive waste is received by the facility. This could eventuate if there is a delay between the construction and operation phases.
Operate a controlled facility
The CEO will require the following information as part of the safety case before a licensing decision can be made
4(a)
Description of the structures, components, systems and equipment of the facility as they have been constructed
4(b)
Final safety analysis report that demonstrates the adequacy of the design of the facility, and includes the results of commissioning tests
4(c)
Operational limits and conditions of the facility
4(d)
Arrangements for commissioning the controlled facility
4(e)
Arrangements for operating the controlled facility
Following construction, the PSAR should be updated to address the design information for the facility including the operational limits and conditions within which the facility must operate. The term 'final SAR' (FSAR) is used for the updated version that must be submitted to ARPANSA with an application for a licence to operate a facility as part of the updated safety case.
Decommission or close a controlled facility
The CEO will require the following information as part of the safety case before a licensing decision can be made
5(a)
Decommissioning plan for the facility
5(b)
Schedule for decommissioning the facility
5(c)
The results of decommissioning activities at the controlled facility
5(d)
Details of any environmental monitoring program proposed for the site
Decommissioning is applicable to a radioactive waste storage facility and to ancillary infrastructure necessary for predisposal management including infrastructure associated with a disposal facility before closure of the facility.
The decommissioning plan should be part of the safety case from the outset and will be refined until such time an application to decommission the facility is submitted. It will at that time also be informed by operational experience including information about any events that might be relevant to the safety of decommissioning.
A final decommissioning report should summarise:
decommissioning undertaken
dismantling of the facility
waste management including clearance of radioactive materials or objects from regulatory control
the final status of the site at the time of release from regulatory control or of conversion to other use
any remaining restrictions on the site.
The final decommissioning documentation should show, as far as practicable, that all radioactive materials present at the beginning of decommissioning are accounted for and their ultimate destination is confirmed.
Release of the site or facility from regulatory control may be achieved progressively for parts of the facility or site or with restrictions to ensure protection of people and the environment. A plan for ongoing control, maintenance and surveillance of any area released with restrictions should be prepared by the licence holder and approved by ARPANSA. Legal and financial arrangements should be made for implementation of the plan.
For a disposal facility the safety case for operation of the facility should consider the safety after closure of the facility. The safety of the disposal facility after closure should take into account the expected range of possible developments affecting the disposal system and events that might affect its performance including those of low probability. Further details of the post-closure phase are described in Section 5.2.2 of this document and specific requirements for the final closure plan are presented in Schedule 1.
The CEO’s consent must be obtained before a licence can be surrendered and a site released from regulatory control.
3. Undue risk
Under paragraph 53(c) of the Regulations, the CEO must consider whether the information provided by the applicant establishes that the proposed conduct can be carried out without undue risk to the health and safety of people and to the environment. For this purpose, the applicant should demonstrate that the radiation risks to people and the environment arising from the proposed conduct have been fully assessed including the probability and magnitude of potential exposures arising from abnormal occurrences.
Guidance on optimisation of protection in terms of radiation doses and risks are given in Section 5 of this regulatory guide. The systematic approach to achieve the appropriate level of protection is captured under Plans and arrangements for managing safety as outlined below.
3.1 Plans and arrangements for managing safety
Objective: The applicant should demonstrate effective systems and processes that provide assurance that the controlled facility can be sited, constructed, operated, decommissioned and closed in a way that does not pose undue risk to the health and safety of people and to the environment.
The management system is key to establishing a system for leadership and management for safety; it should provide assurance that the operator has systems and procedures in place to identify, characterise and manage all safety issues including ranking the relative importance of risks so that available resources are deployed efficiently and effectively.
The management system should be designed to foster and promote a culture of safety which takes into account human factors such as attitudes and behaviour as well as the general mindset by which all workers including senior management approach safety. These factors should interact with the technological and organisational factors in a way that promotes holistic safety (often referred to as systems safety) which is considered a best practice approach to safety management. A holistic approach to safety ensures the technology is safe to use, people perform tasks safely, and the organisation overall is managed safely.
ARPANSA has developed a Holistic Safety Guideline on the implementation of holistic safety to which applicants may refer.
The applicant should include in the safety case information that demonstrates leadership and management for safety, relevant to all safety aspects and licensing phases, documented in a management system
The management system should define how the applicant proposes to manage the controlled facility to ensure health and safety of people and protection of the environment. The applicant should provide the following information as per paragraph 46(1)(d) of the Regulations:
the arrangements for maintaining effective control of the facility
the safety management plan for the facility
the radiation protection plan for the facility
the radioactive waste management plan for the facility
the security plan for the facility
the emergency plan for the facility
the environment protection plan for the facility
The interdependencies between different components of the waste management system and their collective contribution to the over-all safety of the facility should be considered.
In the case of co-located facilities, the management system should address the elements which are common to these facilities and their interrelationships as well as the safety implications of co-location.
The management system should address holistic safety, that is, the human, organisational and technical elements, and their interrelations in managing the facility safely.
4. Net benefit (justification)
Objective: the applicant should demonstrate that the controlled facility provides an overall net benefit.
The principle of justification in the internationally adopted system for radiological protection states that any activity which introduces a radiation source or exposure must do more good than harm, that is, there is net benefit. Under paragraph 53(d) of the Regulations, the CEO must consider whether the applicant has shown that there is a net benefit from carrying out the conduct related to the controlled facility.
For radioactive waste storage or disposal facilities, the analysis of justification should take into consideration the conduct relating to the controlled facility including any predisposal management as well as the risks and benefits of the activities and facilities that generate further waste. For waste that already exists, justification cannot be assessed; however, any decision to manage it should consider optimisation of protection (see Section 5).
The risks associated with the continuation of current practices (the ‘zero option’) and with reasonable alternatives to the proposed system should be considered by the applicant.
It is acknowledged that in many cases, decisions relating to benefit and risk are taken at the highest levels of government11. In other cases, a regulator, such as the CEO of ARPANSA, may determine whether proposed facilities and activities are justified.
The applicant should include in the safety case information that demonstrates that the proposed facility is justified
The applicant should provide:
information on current and future activities generating waste destined for the facility and the benefits and risks associated with the generation of waste that contribute to such waste streams
an analysis of potential alternative technologies than the ones currently generating the waste or other ways by which the same benefit can be achieved with less risks
an analysis of alternative options for managing (predisposal management including storage, and disposal) the current waste inventory and projected waste streams including the option of continuing current practices and the associated risks.
5. Optimisation
Under paragraph 53(e) of the Regulations, the CEO must consider whether the applicant has shown that the magnitude of individual doses, the number of people exposed, and the likelihood that exposures will happen, are as low as reasonably achievable, having regard to economic and social factors. This internationally adopted principle for radiological protection is referred to as optimisation.
Dose limits have been set in Division 2 of the Regulations at levels that provide a high level of protection for individuals from detrimental effects of radiation exposure. The dose limits and provisions regarding averaging times and calculations of committed dose outlined in Division 2 apply in their entirety to facilities covered by this regulatory guide.
Optimisation ensures that the dose limits are very rarely exceeded as exposures are normally optimised far below such limits. Optimisation is often guided by a dose constraint which is set at a fraction of the dose limit and is specific to the activity or facility (the ‘source’) that is the cause of the exposure. Planning, design and management should be such that exposures over this constraint are not expected to occur but are maintained as low as reasonably achievable where economic and social factors are taken into account.
5.1 Protection of workers
Objective: The applicant should demonstrate that systems, structures and components, and the management of the controlled facility provide optimised protection of workers during operation and decommissioning and that worker protection is optimised during monitoring and remedial works including in the post-closure phase of a disposal facility.
The applicant should propose a dose constraint for workers below which protection will be optimised. The expectation is that the constraint would not normally be set higher than 5 mSv effective dose per year12 for workers in a facility for storage or disposal of radioactive waste.
Dose limits apply and optimisation of worker protection should also be implemented during remedial work whether this work takes place during the operation, decommissioning or post-closure phases.
Dose records provide a means of verifying that efforts to optimise radiation protection have been effective.
5.2 Protection of the public
Objective: The applicant should demonstrate that systems, structures and components, and the management of the controlled facility provide optimised protection of the public during operation, decommissioning and post closure.
The engineered barriers should be designed and maintained, and for the long term the natural barriers should be of a nature so that the containment of the radioactive waste will be effective and will withstand reasonably foreseeable disruptive events over the time period the waste poses radiation risks of concern.
The applicant should demonstrate the protective capability of the facility by carrying out exposure modelling based on a set of clearly defined and explained assumptions13. This includes defining and using a representative person, affected by reasonably foreseeable exposures from the facility, or reasonably foreseeable exposures resulting from handling, including transport, of the waste (see ICRP Publication 101a Assessing Dose of the Representative Person for the Purpose of the Radiation Protection of the Public (2006) for details on the representative person).
5.2.1 The operational phase
The applicant should demonstrate that the protective capability is optimised including how different design alternatives have been considered in the optimisation process and support the analysis by exposure modelling. For a storage facility, the design and maintenance during the operational phase should aim to permit abandonment of the site and unrestricted access after decommissioning (‘green field’) or—if so authorised—use for different purposes including for activities that may require management of radiation risks.
5.2.2 Post-closure phase
The post-closure phase for a disposal facility includes the normal and natural evolution of the systems, structures and components that contribute to safety and disruptive natural events that may impact on safety, either immediately or in the future. Disruption may also be caused by inadvertent and planned intrusion, accidents and reckless activities, and intrusion with malicious intent.
Normal evolution of the facility and its surroundings
Processes that govern the performance of the barriers can be foreseen with reasonable certainty and are linked to the features of the facility. The period during which ongoing control of the facility will take place should be defined by the applicant. During this phase, and taking reasonably foreseeable natural events into account, the protective capability of the facility is expected to be at least similar to the protective capability during the operational phase (features, events and processes are commonly referred to as FEPs).
Following termination of controls, or for time periods beyond several tens to a few hundred years (depending on the type of facility), it is reasonable to analyse the facility’s protective capability in terms of risk rather than in terms of exposure or dose.
The concept of radiation risk as used in this regulatory guide considers the probability of an event occurring with the probability of harm (the implications for the health of people) should the event occur. A high probability event with a low probability of harm may thus pose the same risk as a low probability event with high probability of harm. The applicant should define the scenarios that govern the risk estimates. This can be done deterministically by defining likely scenarios and assigning parameter values to FEPs. The analysis can be supplemented by performing a number of realisations in a probabilistic approach to the assessment. Information should be provided on the time frames within which the risk is assessed.
For normal evolution including reasonably foreseeable natural disruptive events, optimisation and use of best available technique should aim at reducing the annual risk for health detriment14 for a member of the public to in the range 10-5 to 10-6 or less (one in a hundred thousand to one in a million). This range takes into account the various means (and inherent uncertainty) in predicting the characteristics, including behaviour and land use of future populations including the representative person, over time periods of centuries and beyond. The applicant should provide information on how the risk may vary over time.
Accidents and severely disruptive natural events
Severely disruptive events include accidents and natural events of a magnitude that is well outside of the ordinary, e.g. seismic events outside the range of what has been recorded or can be reasonably expected or flooding caused by similarly extreme weather conditions. The consequences of multiple and simultaneous events should be analysed as well as the long term consequences of such events for the protective capability of the facility.
The applicant should separately and deterministically assess and record a suite of scenarios that involve accidents and severely disruptive natural events that may result in an annual dose of ≥1 mSv effective dose (annually or in immediate association with the event) if such scenarios exist and explain the rationale for identifying the scenarios.
Human intrusion
Planned intrusion may result from any future attempt to alter the engineered barriers or retrieve the waste or any other reason that today can only be speculated. They would be considered planned actions. The framework for institutional control and preservation of information should be developed with the potential for such future planned actions in mind.
Any design features aimed at facilitating retrieval of waste should not reduce the protective capability of the facility.
The applicant should address possible scenarios involving inadvertent human intrusion into the disposal facility in the post-closure phase. The consequence of intrusion for the protective capability of the facility should be analysed.
If such intrusion is expected to lead to an annual dose of less than 1 mSv effective dose to the intruder or those living close to the site then efforts to reduce the probability of intrusion or to limit its consequences are likely not warranted.
Where it is calculated that inadvertent human intrusion could result in doses of between 1 and 10 mSv effective dose for any human associated with the intrusion (annually or in immediate association with the intrusion) further evaluation of the particular scenario is needed and reasonable efforts may be warranted to reduce the probability of intrusion or to reduce the consequences.
If doses of greater than 10 mSv effective dose associated with the intrusion are calculated for an individual from a plausible but inadvertent human intrusion scenario (annually or in immediate association with the intrusion) additional controls should be put in place to further limit the possibility of intrusion or to limit the consequences to below that dose figure. This may involve re-design of the facility, changes to the waste acceptance criteria or segregation of the radioactive substances giving rise to the higher dose.
Deliberate intrusion may also arise from acts with malicious intent. The concern here is primarily with the safety of those indirectly affected by the intrusion. The arrangements for safety should reduce the worker, public and environmental risks associated with such intrusion to levels that are as low as reasonably achievable where economic and social factors are taken into account.
Remediation preparedness
For any remedial actions that are deemed justified following reckless actions, accidents and disruptive events including human intrusion a reference level of 10 mSv annual effective dose or less should be applied for protection of the public. Remedial actions should be planned and optimised so that the resulting annual effective dose is below the selected reference level. Worker exposures must be below the dose limit for workers and should be optimised. Information on remediation preparedness should include the following, as relevant:
division of responsibilities for remediation
the role of stakeholders
approaches to defining remediation targets and end states as well as generic waste management plans
potential methods and technology available for environmental remediation.
Time frames
The applicant may impose a time cut-off in the assessment of passive safety. The reason for the cut-off should be explained.
In the case of time frames beyond several hundreds of years, increased attention needs to be placed on analysis of implications for safety of long-term climatic and other environmental trends in order to form a view on the appropriateness of the protective capability of the facility.
The applicant should include as part of the safety case information that demonstrates that all reasonable steps have been taken to ensure that protection of workers and the public is optimised
The applicant should optimise the protection of workers and in doing so:
establish dose constraints to guide optimisation efforts
optimise worker protection during any monitoring or remedial work
The applicant should optimise protection of the public in the operational phase of a storage or disposal facility and in doing so:
model exposures of representative individuals and define what assumptions that have been made about exposure pathways and their characteristics, and about the characteristics of the exposed groups including the representative individuals.
The applicant should optimise protection of the public and apply best available technique to the design and to the safety of the post-closure phase of a disposal facility and in doing so:
aim for reducing risks of detriment to between 10-5 and 10-6 per annum or less, including during reasonable foreseeable natural disruptive events, using the nominal risk coefficients in ICRP Publication 103 and provide information on the assumptions used in the risk calculations
identify scenarios including disruptive events, accidents, and intrusion (inadvertent or with malicious intent) that may lead to effective doses over 1 mSv annually or in association with the event
for intrusion scenarios leading to effective doses in excess of 10 mSv (annually or in association with the event) consider alternative designs or methods to segregate the waste
for planned remedial actions, comply with dose limits for workers and optimise protection against a reference level of 10 mSv effective dose per year or less.
The applicant should carry out calculations demonstrating the protective capability of a disposal facility in the future and in doing so:
analyse the features, events and processes governing the protective capability of the engineered and natural barriers over a time period that is commensurate with the hazard of the disposed waste.
5.3 Protection of the environment
Objective: The applicant should demonstrate that the systems, structures and components, and the management of the controlled facility provide protection of the environment and that the facility does not adversely impact an area that has special environmental attraction or appeal, is of notable ecological significance, or is the known habitat of rare fauna or flora.
In order to assess the impact of a proposed radioactive waste storage or disposal facility on the environment the applicant should undertake a screening assessment of exposures to wildlife. If a screening assessment that uses a cautious approach indicates that incremental exposures to relevant wildlife in the natural environment are likely to be below a dose rate of 10 microGy per hour, no further assessment will be deemed necessary15. If the assessment indicates higher dose rates, further assessments should be performed to estimate the potential level of impact on wildlife. Guidance is provided in ARPANSA RPS G-1 Guide for Radiation Protection of the Environment (2015).
An environmental management plan should be established for the disposal site prior to commencement of construction and operation. The purpose of the plan is to set out management objectives and practices which will provide for the safe and environmentally sound management of the facility during its construction, operational and post-operational phases.
Time frames and scenarios used for the analysis of long-term protection of people should be applied also when analysing long-term protection of the environment.
The applicant should include as part of the safety case information that demonstrates that the environment is protected
The applicant should characterise the environment, including any unique features requiring particular attention in terms of conservation that may influence the feasibility of the site.
The applicant should, before the construction of a facility, establish baseline information of the site regarding its radiological characteristics, to inform the development of the environment management plan and environmental monitoring.
The applicant should, as parallel to the optimisation of protection of people, consider exposures of organisms in the natural environment using scenarios and time frames that have been used when analysing long-term protection of people and in doing so:
analyse the characteristics of the natural and semi-natural environment in the facility’s surroundings
take into consideration that dose rates incurred by wildlife in such environments below 10 µGy per hour and determined or predicted using cautious approaches and methodologies may serve as an indicator that wildlife is adequately protected.
5.4 Security
Objective The applicant should demonstrate that systems are in place to prevent unauthorised access, theft and acts with malicious intent including actions that would contribute to proliferation of nuclear material considering the security vulnerabilities of the controlled facility and entire system for waste management.
The approach to security should be guided by the optimisation principle and be benchmarked against the dose and risk reduction strategies outlined above. The interaction and interface between measures to ensure safety on one hand and security on the other, should be taken into consideration so that actions taken to ensure security do not inadvertently impact on safety and vice versa.
The applicant should include as part of the safety case information that demonstrates that people, property, society and the environment is protected from malicious intent
The applicant should:
submit a security plan that covers security issues including transport of waste where relevant
assess and manage any conflicts or tension between security and safety
6. Capacity to comply
Objective: The applicant should demonstrate that adequate capacity is sustained for the full life-cycle of the controlled facility and records are established and preserved for the future.
Under paragraph 53(f) of the Regulations, the CEO must consider whether the applicant has shown a capacity for complying with the Regulations and the licence conditions that would be imposed under section 35 of the Act.
The applicant should demonstrate that it has the capacity of managing safety over the life-time of the facility. It should demonstrate adequate human and financial resources, the necessary skills for leadership and management of safety, and long-term sustainability. It should also provide information of its record of managing similar facilities or relevant information that provides confidence in its ability and capacity to do so.
The approximate timing and conditions for termination of the responsibility of the operating organisation should be defined for example, after decommissioning or closure. Where relevant, the terms and conditions for continued institutional control should be clarified.
Records relevant to safety should be established and arrangements should be made for their long-term maintenance including determining locations where the records are to be kept. Commonwealth government agencies must comply with the requirements of the Archives Act 1983 (Cwlth).
The applicant should demonstrate adequate capacity to sustain safety over the life-cycle of the facility
The applicant should, unless the information is already available to ARPANSA, demonstrate that:
it is adequately resourced financially
possesses the necessary competencies, skills and experience
it is able to sustain its activities including safety during the expected time of ongoing control of the facility.
Safety-related records should be established and arrangements made for their long-term maintenance.
Schedule 1: Information that should be submitted as part of the safety case
General information relevant to all stages of a controlled facility
The applicant should submit a safety case with the licence application that includes:
the information requested in section 46 of the Regulations relevant to the specific licensing stage (see Section 2.2)
all safety-related arguments the applicant draws on in support of the application. A safety case document may reference detailed supplementary documentation but should be comprehensive enough to allow all stakeholders to form a view on the safety of the facility
a summary in plain language to facilitate communication during the consultation process16.
The safety case should be updated for each new stage in the licensing process, drawing on input during consultation and experience gained during establishment of the facility, include information on remaining unresolved issues and the plan towards their resolution.
It should contain enough information on future licensing stages to allow for an informed decision on safety during the facility’s life cycle.
Compliance with legislative and regulatory requirements
these include the Act and Regulations, other Acts as relevant, codes (RHS and RPS) as relevant, and to take into account ARPANSA regulatory guides as relevant.
Approach to international best practice
the radiation protection, and nuclear safety and security objectives as a part of the siting, design, operation, decommissioning and closure; compared with those laid out in the international framework for safety, security and radiation protection documented in international standards (e.g. IAEA safety standards and nuclear security guidance)
technical standards for construction, materials and other features, relevant to safety
experience from siting, construction, operation, decommissioning and closure of similar facilities in countries with an advanced infrastructure for safety.
Protection of the health and safety of people and of the environment
demonstration that the application meets the health and safety objectives of relevant legislation
justification for the application in terms of net benefit, i.e. that there is more good than harm (see Section 4)
demonstration that protection is optimised and that the environment is protected (see Section 5)
a safety assessment including an iteration of the safety analysis report (SAR) relevant to the licensing stage
an analysis of long-term safety taking into account foreseeable natural events and severely disruptive events including reckless action, accidents and events associated with human intrusion (see Section 5)
a management system outlining the interdependencies between safety factors within the controlled facility and within the system for waste management including systematic consideration of human factors and the human-machine interface to promote holistic (or system) safety (see Section 3).
Specific information relevant to an application to prepare a site for a controlled facility
Conceptual design of the facility and information on the waste management system including:
design characteristics of the proposed facility and information on how the facility interacts with the site so that any introduction of unreasonable design requirements to compensate for a less favourable site can be avoided
descriptions of the considered disposal options and the considerations leading to the applicants preferred option including choice of site and design of the facility
waste management system including: facilities for storage and disposal; waste inventory and future waste streams destined for the facility; transport arrangements and likely paths; any ancillary facilities for predisposal management, e.g. for conditioning of waste
potential safety and security issues from co-location of facilities at new or existing sites, where applicable
for a storage facility: the operational life span, plans covering final disposal including transport to the disposal facility, necessary ancillary facilities for predisposal management and contingency planning for delays in the establishment of a disposal facility
for a disposal facility: the intended period of institutional control
the availability of resources over the lifetime of the proposed waste facility including for decommissioning or closure as appropriate.
Description of the radioactive waste to be managed in the facility
the waste (form, volume, radionuclide inventory, chemical composition, toxicity, stability and all other physical, chemical and radiological characteristics that are relevant for reviewing the safety of the facility) currently in store that is destined for the facility
the waste and its characteristics (see above) anticipated for the facility during its operational life-time and whether the facility is a store or a disposal facility
the waste acceptance criteria including the characteristics of the waste (e.g. mobility), waste form and the containment system; design and construction of packages; provisions for retrievability of packages; design provisions for criticality safety where nuclear materials are present.
Site characteristics
characteristics of the proposed site including seismology, meteorology, hydrology, geology, demography, biology, hazards and human actions, and the environment’s ability to serve as a barrier that provides protection for the facility and retards migration of radionuclides
assessment of the site taking into account the implications of the site characteristics for the radiological impact of the facility on the surrounding population and the environment during normal operation and anticipated natural events.
Reference accident
the identification of a severe hypothetical event beyond the design basis of the facility (design extension conditions) and assessment of its radiological consequences and mitigation.
Specific information relevant to an application to construct a controlled facility
Engineered barriers for a storage or disposal facility
the approach to defence in depth including a multi-barrier approach to ensure containment and the use of redundancy, independence and diversity in the design of the safety system to ensure that the design is balanced i.e. that safety at defence in depth level 3 is not relegated unduly to defence in depth levels 4–5
selection and optimisation of a system of engineered barriers including consideration of best available technology as appropriate including the waste containers, the waste conditioning materials and matrix, the use of vaults or trenches made from materials with specific properties, drainage systems, cover layers, and other barriers
design features to facilitate waste handling, storage and transport as well as inspection, and if considered appropriate, retrieval of waste from a disposal facility
design consideration (for a waste store) of aspects that may facilitate subsequent extension of the life of the facility and eventual decommissioning.
Items important for safety
items important to safety are designed to a standard and quality that is commensurate with their categorisation by safety significance according to the appropriate national and international standards taking into account effects of ageing during operational states and accident conditions.
Access control, physical security and surveillance
design provisions for physical security and access control appropriate for the radioactive material present in the facility
design provisions for monitoring and surveillance.
Verification and validation
a program for design verification and validation to confirm that the design is adequate and is in accordance with the design specifications including the closure features
a program for managing uncertainties including their characterisation with respect to their source, nature and importance
the process for validation and verification of computer codes.
Design-basis accident
provisions that the design ensures that the safety systems accommodate design-basis accidents and there are provisions to ensure that for design-basis accidents, the radiological consequences if any, would be minor and within prescribed limits and that no off-site emergency response would be required following any design-basis accidents
design-basis safety limits are not exceeded in the event of a design-basis accident
likelihood is extremely small of any beyond-design-basis accident (design extension conditions) that could have serious radiological consequences
design provisions for limiting the progression and mitigating the consequences of beyond design basis accidents.
Specific information relevant to an application to possess or control a controlled facility
None except as specified in section 46(2) of the Regulations.
Specific information relevant to an application to operate a controlled facility
Final waste acceptance criteria (for a disposal facility)
the final waste acceptance criteria; these will inform ARPANSA whether the characteristics of the waste are aligned with the operational and long-term safety features of the facility.
Operating procedures and arrangements
operating procedures and arrangements for the facility including details of operational limits and conditions derived from the safety analysis of the facility
results from tests of items important for safety and commissioning tests.
Confirmed hazard categorisation
Hazard category F1: where there is no potential for significant consequences outside the facility
Hazard category F2: where there is potential for significant consequences on the site outside the facility but not outside the site
Hazard category F3: where there is potential for significant consequences outside the site.
Specific information relevant to an application to decommission a storage facility
Final decommissioning plan
final decommissioning plan addressing the strategy and processes as well as the justification for selecting a particular strategy
results of radiological characterisation of structures, systems and components that will be dismantled and the results of the hazard analysis
provisions for handling, treatment, packaging and transport of waste generated from decommissioning activities
final decommissioning report demonstrating that the site or the facility can safely be released for the purpose stated in the decommissioning plan
post-decommissioning radiological survey reports demonstrating that the radiation doses specified in the decommissioning plan are not exceeded.
Specific information relevant to an application to close a disposal facility
Final closure plan
final closure plan describing the institutional controls (restrictions, monitoring and surveillance, maintenance and any remedial actions, and information preservation) for the post-closure period
a radiological impact assessment for the post-closure period, using deterministic and probabilistic analyses as appropriate.
Appendix 1: Completing the application form
This section is designed to guide an applicant through the licence application form
Section A: Applicant information
Name of department or Commonwealth body
Provide the name of the Department or Commonwealth Body on behalf of which the application is being made. Further information may be included for ease of identification e.g. Division, Branch, Section etc.
Portfolio
Provide the name of the Commonwealth ministerial portfolio in which the Department or Commonwealth Body resides.
Applicant
The application must be made by either:
a) the Secretary, Chief Executive Officer, or an equivalent person, of the Department or Commonwealth Body (the applicant)
b) a person authorised by the applicant to lodge an applicationA1.
In the case of (b), the application must include a copy of the authorisation.
The applicant must provide their full name, position and business address.
Nominee
If the applicant is sufficiently removed from the facility that they cannot demonstrate effective control, the name and contact details of a person more directly in control of the facility (the nominee) must be provided. The nominee must be in effective control of the facility. Generally the nominee will be the manager of a division or agency’s operation at the site of the proposed activity. If a nominee is appointed, an organisational chart must be provided showing the relationship of the nominee to the applicant and the operators.
Radiation Safety Officer
This is an individual appointed by the applicant to supervise radiation safety in relation to the controlled facility, controlled apparatus and/or controlled material for which the licence is sought. This person must be technically competent in radiation protection matters relevant to the facility and any associated sources. Evidence of competency must be included with the application. If there is more than one radiation safety officer, the details of other radiation safety officers must also be provided.
Declaration
The declaration must be signed by the applicant or authorised person.
Section B: Kind of nuclear installation and type of authorisation
The applicant must indicate the kind of nuclear installation and type of authorisation for which a licence is sought.
Section C: Facility details
The applicant must provide a detailed description of the facility and its site including the site address. The purpose of the facility must be described and specific information relevant to the type of authorisation sought must be provided. Applicants may include this information in the application form or provide references as to where this information can be found in supporting documentation.
Type of authorisation
The applicant must complete the section relevant to the type of authorisation sought (see Section 2). References as to where this information can be found in the accompanying documentation may be provided.
Section D: Plans and arrangements
The applicant must have plans and arrangements for managing the controlled facility to ensure the health and safety of people and protection of the environment. The plans and arrangements must be a comprehensive program of policies and procedures that demonstrate how safety and security will be assured. A brief description of what is expected in plans and arrangements is provided below. For more detailed information, applicants must refer to the Regulatory Guide: Plans and arrangements for managing safety.
1. Effective control arrangements
The applicant must describe arrangements for maintaining effective control over the facility. This must address issues such as organisational arrangements, resources and management systems.
2. Safety management plan
The applicant must describe the administrative arrangements for managing the safety of the facility. Issues such as safety culture, safety of premises and equipment, competency and training, incidents and accidents, auditing, and record keeping must be addressed.
3. Radiation protection plan
Radiation protection policies and procedures must be set out in a radiation safety manual or management plan and in specific operating procedures.
The radiation protection plan must cover issues such as principles of radiation protection, planning and design of the workplace, classification of work area, local procedures, radiation monitoring of individuals and the workplace.
4. Radioactive waste management plan
A full description and anticipated amounts of any radioactive wastes, including discharges arising from the proposed conduct and the arrangements for the safe handling, treatment, storage and disposal of any such waste must be set out in a radioactive waste management plan.
5. Security plan
Arrangements for the security of the facility and any associated sources to prevent theft, damage or unauthorised use or access must be provided. These arrangements must demonstrate how the security of the facility and any associated sources will be maintained and how periodic inventory checks will be undertaken to confirm that all sources are in their assigned locations and are secure. See also Section 5.4.
6. Emergency plan
Emergency arrangements must be developed for all foreseeable emergencies such as dispersion of materials, overexposure of operators, or theft or loss of controlled material. The arrangements must include the responsibilities of all parties in the event of an emergency, contact arrangements, emergency procedures, emergency equipment and reporting arrangements. Where necessary, arrangements for involving external agencies such as police and other emergency services must be included.
The plan must include arrangements for testing the emergency arrangements through regular reviews and exercises, and rectifying any deficiencies found in the emergency plans.
7. Environment protection plan
Arrangements must be developed for the protection of wildlife populations and ecosystems in parallel with radiation protection of people, consistent with international best practice. The arrangements must include identification of all potential exposure scenarios and pathways to the environment and affected biota with environmental radiological assessments of wildlife in their natural habitats based on the concept of reference organisms. See also Section 5.3.
Section E: Associated sources
Sources that are part of, used in connection with, produced by, incorporated in, stored in, or disposed of in, a facility do not require a separate source licence, but must be authorised by the facility licence.
Not all facilities have associated sources but where they do, the applicant must indicate the kind of controlled material and/or controlled apparatus in Section E of the application. Common types of sources in facilities are calibration sources. For sealed sources, a copy of any source certificate or special form certificate should accompany the application as per item 1(d) of the table in subsection 47(2) of the Regulations.
Section F: Source details
The details of any sources associated with the facility must be recorded in a Source Inventory Workbook (SIW). The SIW is the form approved by the CEO for maintaining source records. It is an Excel spreadsheet available from the ARPANSA website. An explanation of terms and required information appears in the first worksheet of the SIW. If in doubt, contact ARPANSA for advice. The completed SIW is to be submitted electronically with the application.
Note: For sealed sources, a copy of any sealed source certificate or special form certificate should be provided.
Section G: Matters to be taken into account by the CEO
Under subsection 32(3) of the Act, the CEO, in deciding whether to issue a facility licence, must take into account certain matters prescribed in the Regulations and international best practice in relation to radiation protection and nuclear safetyA2. Division 5 of the Regulations lists the matters that the CEO must take into account. Section G of the application form is where an applicant must provide this information.
Undue risk – see Section 3
Net benefit – see Section 4
Optimisation – see Section 5
Capacity to comply – see Section 6
Application fee
The application is not valid without the appropriate fee. Applicants should refer to Division 4 of the Regulations to determine the appropriate application fee.
Assessment of the application cannot begin until the fee is received. Arrangements should be made for electronic payment of the fee.
Once an application has been submitted it will be examined to ensure that all the necessary information has been included and that it is properly signed and that the application fees have been paid. If so, the applicant will receive a letter of acknowledgment. If any of the basic information is not included, the applicant may be contacted for further information or the application and application fee may be returned with a letter describing the omission.
As soon as practicable after receiving an application for a facility licence, and once it has been determined to be complete, section 48 of the Regulations requires the CEO to publish a notice in a national daily newspaper and on the ARPANSA website, stating his intention to make a decision on the application. If the application relates to a nuclear installation, the CEO must include in the notice:
an invitation to people and bodies to make submissions about the application
a period for making submissions
procedures for making submissions.
Applications are then forwarded to a Regulatory Officer for assessment. Where matters require clarification, the Regulatory Officer will contact the applicant or nominee. The Regulatory Officer may also consider that an inspection or site visit is necessary and may contact the applicant to make arrangements.
Once the Regulatory Officer has reviewed and assessed all the information provided, a Regulatory Assessment Report (RAR) is produced. This report will address the matters to be taken into account by the CEO of ARPANSA in accordance with subsection 32(3) of the Act, namely international best practice in relation to radiation protection and nuclear safety and the matters specified in the Regulations. Division 5 of the Regulations specifies those matters. They are:
a) whether the application includes the information asked for by the CEO
b) whether the information establishes that the controlled apparatus or material can be dealt with without undue risk to the health and safety of people, and to the environment
c) whether the applicant has shown that there is a net benefit from the proposed conduct
d) whether the applicant has shown that the magnitude of individual doses, the number of people exposed, and the likelihood that exposure will happen, are as low as reasonably achievable, having regard to economic and social factors
e) whether the applicant has shown a capacity for complying with the Regulations and the licence conditions that would be imposed under section 35 of the Act
f) whether the application has been signed by an office holder of the applicant, or a person authorised by an office holder of the applicant
g) In the case of a nuclear installation, the content of any submissions made by members of the public about the application.
The RAR will make a recommendation to the CEO (or delegate) about whether to issue a licence and may recommend the licence conditions to be imposed under section 35 of the Act. All relevant documentation is sent to the decision maker. The applicant will be advised in writing of the decision. The CEO (or delegate) will publish a ‘statement of reasons’ for the decision on the ARPANSA website.
Under section 37 of the Act, a licence may be issued for an indefinite period or for a specified period. Once issued a licence remains in force until it is cancelled or surrendered or the specified period has elapsed.
Appendix 3: Appealing a licence decision
Section 40 of the Act describes the rights of review available to eligible persons in respect of licence decisions made by the CEO. The following decisions are reviewable:
a) to refuse to grant a licence
b) to impose conditions on a licence
c) to suspend a licence
d) to cancel a licence
e) to amend a licence
f) not to approve the surrender of a licence
g) to issue a licence for a particular period, rather than for a longer period or indefinitely h) not to extend the period for which a licence was issued.
An eligible person in relation to a decision to refuse to grant a licence means the person who applied for the licence, and in relation to any other licence decision, it is the licence holder.
Review by the Minister
If an applicant wishes to have a licence decision reviewed, the applicant may request the Minister for Health to review the decision. The request must be in writing and be given to the Minister within 28 days of the making of the licence decision. Once a request for review has been lodged, the Minister must reconsider the licence decision and confirm, vary or set aside the decision.
The Minister is taken to have confirmed the licence decision if the Minister does not give written notice within 60 days of the request.
Review by the Administrative Review Tribunal (ART)
An application may be made to the ART for review of a decision of the Minister.
1 Near-surface disposal facility; facilities established on or close to the surface.
2 Including, for example, storage and disposal of waste in a National Radioactive Waste Management Facility (NRWMF), should plans to establish a NRWMF currently under development by the Department of Industry, Innovation and Science be pursued.
3 See ARPANSA’s website www.arpansa.gov.au for guidance relevant to other types of radioactive waste than covered in this Regulatory Guide.
4 The term biosphere is often used in connection to the assessment of safety of facilities for storage and disposal of radioactive waste, meaning the part of the environment where organisms can be found.
6 Radiation risk means detrimental health effects of exposure to ionising radiation including the likelihood of such effects occurring, and other risks including environmental risks, that might arise from exposure to ionising radiation; the presence of radioactive material (including radioactive waste) or its release to the environment; or a loss of control over a nuclear reactor core, nuclear chain reaction, radioactive source or any other source of radiation; alone or in combination (see RPS F-1, Fundamentals for Protection Against Ionising Radiation (2014)).
7 Consultation required under section 48 of the Regulations, where the CEO is obliged to consult following receipt of a complete application. This will include publishing a notice in a national daily newspaper and on the ARPANSA website, stating their intention to make a decision on the application. The CEO must include in the notice: an invitation to people and bodies to make submissions about the application; a period for making submissions and procedures for making submissions [see Appendix 2]
8 See Section 5, Information for Stakeholders, page 31 of ICRP Publication 122.
9 Refer footnote 7.
10 An environmental impact assessment can be conducted in parallel with the licence application however a licensing decision will not be made until the EIS and its outcomes have been submitted to ARPANSA (see Section 2.1).
12 The effective dose is a risk-related quantity used for radiation protection purposes (not risk assessments) that integrates current knowledge of biological effectiveness of different types of radiations, and the likelihood of developing disease in different organs. It is measured in units with the special name sievert (Sv). For further specifics of radiation and tissue weighting factors, and other matters that relate to dosimetry and radiation risks, information in ICRP Publication 103 The 2007 Recommendations of the International Commission on Radiological Protection, Annals of the ICRP 37 (2-4) serves as the main reference.
13 A prudent approach could be to use reasonably cautious, yet realistic, assumptions in deterministic assessments; the use of overly pessimistic assumptions in successive iterations provides little information on actual safety performance and protective capability. In a probabilistic approach, a comprehensive analysis is made of failure scenarios to quantify risks. The applicant may chose the approach or a combination of approaches, but must provide justification for the chosen methodology and define the assumptions made.
14 The detriment adjusted nominal risk coefficient at low dose rates, applicable to the whole population and to stochastic effects (all cancers and heritable effects); of 5.7% per sievert given in Table 1 of ICRP Publication 103 must be used.
15 There is no risk-related quantity for radiation protection of organisms in the natural environment; hence the physical quantity absorbed dose is used. The absorbed dose is measured in units of joule per kg of absorbing matter, with the special name gray (Gy).
16 Refer footnote 7.
A1 See paragraph 45(b) of the Regulations
A2 Under paragraph 53(h) of the Regulations, the CEO will also take into account the content of any submissions made by members of the public about the application, under a notice issued under section 48 of the Regulations
