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IAEA DS509 - Specific Safety Guides (NS-G-4.1, NS-G-4.2, NS-G-4.3, NS-G-4.4, NS-G-4.5, NS-G-4.6, SSG-10, SSG-37)

ARPANSA coordinates comments on behalf of Australia on IAEA draft documents. We provide feedback to the IAEA through Safety Standards Committee members.

ARPANSA requests comments on drafts in relation to:

  • Relevance and usefulness. Are the stated objectives appropriate, and are they met by the document?
  • Scope and completeness. Is the stated scope appropriate and adequate to cover the document?
  • Quality and clarity. Do the requirements/guidance represent the current consensus among specialists in the field? Are they expressed in a clear and coherent way?

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The Issue
Start/End Date: 
Tuesday 28 April 2020 - 15:00 to Sunday 31 May 2020 - 17:00

ARPANSA coordinates comments on behalf of Australia on IAEA draft documents. The IAEA is seeking comments from their member states on proposed changes to the following eight documents:

  1. IAEA Safety Standards Series No. NS-G-4.1, Commissioning of Research Reactors, IAEA, Vienna (2006)
  2. IAEA Safety Standards Series No. NS-G-4.2, Maintenance, Periodic Testing and Inspection of Research Reactors, IAEA, Vienna (2006)
  3. IAEA Safety Standards Series No. NS-G-4.3, Core Management and Fuel Handling for Research Reactors, IAEA, Vienna (2008)
  4. IAEA Safety Standards Series No. NS-G-4.4, Operational Limits and Conditions and Operating Procedures for Research Reactors, IAEA, Vienna (2008)
  5. IAEA Safety Standards Series No. NS-G-4.5, The Operating Organization and the Recruitment, Training and Qualification of Personnel for Research Reactors, IAEA, Vienna (2008)
  6. IAEA Safety Standards Series No. NS-G-4.6, Radiation Protection and Radioactive Waste Management in the Design and Operation of Research Reactors, IAEA, Vienna (2008)
  7. IAEA Safety Standards Series No. SSG-10, Ageing Management for Research Reactors, IAEA, Vienna (2010)
  8. IAEA Safety Standards Series No. SSG-37, Instrumentation and Control Systems and Software Important to Safety for Research Reactors, IAEA, Vienna (2015).

The IAEA Safety Standards related to the safety of research reactors include IAEA Safety Standards Series No. SSR-3 Safety of Research Reactors (2016) and eleven Specific Safety Guides (hereafter referred to as Guides). These Guides were all published before SSR-3 and represent the international consensus on the safety of research reactors which existed at the respective date of publication. These Guides have been extensively used as a basis for the safety assessments conducted during the IAEA Integrated Safety Assessment of Research Reactors (INSARR) missions and were also used by ARPANSA as references when establishing national safety regulations and safety policies and practices of research reactors.

The gap analysis carried out to compare the requirements of SSR-3 with its predecessor NS-R-4 indicated that the relevant Guides have to also be revised to reflect the changes introduced in SSR-3. 

What are the Guides used for?

The purpose of individual Guides is to provide recommendations for research reactor operating organisations on how to meet the specific safety requirements in the respective areas of design, operation and management. 

ARPANSA uses the Guides for assessment of applications to licence nuclear installations and to make relevant changes to licensed facilities. Content from the guides is incorporated into the ARPANSA performance objectives and criteria which are applied during facility inspections.

Justification of revision

The revision of the Guides will take into consideration the following: 

  • Revisions implemented in the General Safety Requirements, other IAEA Safety Standards and, in particular, the new and modified requirements in SSR-3 since publication of the Guides
  • Structure of the IAEA Safety Standards
  • Feedback from the users of the IAEA Safety Standards related to research reactors
  • Use of these Guides for subcritical assemblies which are now in the scope of SSR-3
  • Lessons from the accident at the Fukushima Daiichi nuclear power plant and other events in the nuclear industry including those occurring at research reactors that were reported to the Incident Reporting System for Research Reactors
  • Experience gained with INSARR missions.

More specifically, amendments of the Guides are needed to address the following:

  1. Update to references.
  2. As mentioned above, there are several new requirements in SSR-3 and others have been substantively modified from their original form in NS-R-4. These requirements are not fully addressed in the Guides, particularly Req. 22 Design Extension Conditions; Req. 55 Emergency Response Facilities on the Site; Req. 76 Material Conditions and Housekeeping; and Req. 90 Interfaces between nuclear safety and nuclear security.
  3. Some statements in the Guides that are expressed as ‘should’ statements may now duplicate some requirements of SSR-3. Such statements should be carefully checked and either removed or modified to make them useful recommendations supporting the appropriate requirements.
  4. IAEA Safety Standards Series No. SSG-22 Use of a Graded Approach in the Application of the Safety Requirements for Research Reactors was published in 2012. The Guides proposed for this revision were all published before SSG-22 (except SSG-37) and contain information about applying a graded approach in their respective areas. This information needs to be removed from the Guides and consolidated in a harmonised manner in a revision to SSG-22 that will be proposed separately.
  5. The publication of SSR-3 expanded the scope of the safety requirements for research reactors to include subcritical assemblies. As they were all published prior to SSR-3, the Guides do not provide explicit guidance about how the safety requirements are implemented for subcritical assemblies. Although most requirements in SSR-3 are universally applicable to research reactors and subcritical assemblies, SSR-3 makes several explicit references to the safety of subcritical assemblies (for example, SSR-3, Paras. 6.62 and 6.66). The Guides need to be updated to address subcritical assemblies in general and the specific references in SSR-3.
  6. Currently NS-G-4.6 covers radioactive waste management in the design and operation of research reactors. IAEA Safety Standards Series No. SSG-40 Predisposal Management of Radioactive Waste from Nuclear Power Plants and Research Reactors was published in 2016 and also contains guidance related to managing radioactive waste generated at research reactors. An analysis of the guidance and information in NS-G-4.6 and SSG-40 was made to assess whether the topic of waste management could be removed from NS-G-4.6. The analysis showed that there is some overlap between the Guides (e.g. information in NS-G-4.6 on sources of radioactive waste at research reactors was duplicated in SSG-40) but in general SSG-40 provides a more generic treatment of the topic while NS-G-4.6 provides more detailed guidance specifically for research reactors. This is consistent with the scope of SSG-40 which covers ‘predisposal management of all types of radioactive waste generated at nuclear power plants and research reactors’ and ‘all stages in the lifetime of a waste management facility’. 

    The issue of combining radiation protection aspects of NS-G-1.13, WS-G-2.1 and NS-G-4.6 was also considered. As a result of the analysis, it is recommended to retain the detailed guidance in NS-G-4.6 and add references to the additional guidance (e.g. in SSG-40 Section 3 Roles and Responsibilities and Section 4 Integrated Approach to Safety which provide additional guidance beyond what is in NS-G-4.6 Section 9 Organizational Aspects.) This approach will provide target users with detailed and user-friendly guidance for radioactive waste management in the design and operation of research reactors while benefitting from the additional guidance for waste management facilities in SSG-40.
  7. In some cases the Guides need to be updated to better reflect the current operational practices at research reactors and the state-of-the-art in relevant technologies.
  8. An analysis of the guidance and information in SSG-10 and NS-G-4.2 was made to assess whether the two documents should be combined. Ageing management is one of the main issues facing the worldwide fleet of research reactors with more than 40% exceeding 50 years of operation. The analysis indicated that separate guidance is warranted on ageing management and on maintenance, periodic testing and inspection of research reactors to support Member States to enhance safety in these two separate and distinct areas.

Main revisions to the Guides 

The revised Guides will be published as individual Guides and retain their current structure with a few exceptions. It is possible that during the revision process, changes in the structure of individual Guides will be identified to improve their user-friendliness and better align with the structure and content of SSR-3.

Guide Main revisions
NS-G-4.1

This Guide will cover commissioning of research reactors (and major modifications and new utilization activities) and provide recommendations and guidance mainly related to implementing Requirements 1, 5, 12, 24, 30, 36, 40, 51, 55, 67, 73, 74, 82 and 83 of SSR-3.

Changes also include standardisation of the format and clarification of the scope of the commissioning stages for subcritical assemblies. The document revised guidance on how the specific topic of the Guide is covered in the management system.

NS-G-4.2

This Guide will cover maintenance, periodic testing and inspection of research reactors and provide recommendations and guidance mainly related to implementing Requirements 24, 31, 37, 51, 63, 67, 69, 70, 71, 72, 74, 77, 80, 81, 82, 84, 87, 88 and 90 of SSR-3.

The document now better aligns with other Guides and requirements such as GSR Part 2, GS-G-3.1, GS-G-3.5.

NS-G-4.3

This Guide will cover core management and fuel handling for research reactors and provide recommendations and guidance mainly related to implementing Requirements 7, 9, 15, 38, 39, 41, 44, 45, 58, 63, 71, 74, 77, 78, 82, 87 and 90 of SSR-3.

The revision further improves guidance on subcritical assemblies, responsibilities of management, management resources and eliminates repetitions with GS-G-3.1 and GS-G-3.5.

NS-G-4.4

This Guide will cover operational limits and conditions and operating procedures for research reactors and provide recommendations and guidance mainly related to implementing Requirements 6, 18, 20, 21, 24, 35, 41, 45, 50, 67, 69, 70, 71, 72, 74, 75, 77, 78, 81, 82, 83, 84, 85, 87, 88 and 90 of SSR-3.

Operating limits and conditions for subcritical assemblies are added. The changes also better align discussions of graded approach with the new text in SSR-3 referencing subcritical assemblies. The document elaborates on procedures for use during accident conditions.

NS-G-4.5

This Guide will cover the operating organization and the recruitment, training and qualification of personnel for research reactors and provide recommendations and guidance mainly related to implementing Requirements 2, 3, 4, 5, 6, 11, 67, 68, 69, 70, 76, 79, 81, 82, 87 and 90 of SSR-3.

The management system for research reactors is now more comprehensively treated in this section 2, as opposed to the other Guides which will provide summary information and specific guidance for the specific topics of the Guides. Guidance on subcritical assemblies is added. Repetition with GS-G-3.1 and GS-G-3.5 has been removed.

NS-G-4.6

This Guide will cover radiation protection and radioactive waste management in the design and operation of research reactors and provide recommendations and guidance mainly related to implementing Requirements 8, 15, 34, 43, 57, 59, 69, 70, 71, 77, 84 and 85 of SSR-3.

Guidance on subcritical assemblies has been added. Terminology is now more consistent with GSR Part 3.

SSG-10

This Guide will cover ageing management of research reactors and provide recommendations and guidance mainly related to implementing Requirements 9, 10, 17, 24, 29, 37, 38, 77, 86 and 87 of SSR-3.

The revision refocuses guidance on the specific topic of the safety guide following the structure of GSR Part 2, GS-G-3.1 and GS-G-3.5. It also eliminates repetition with GS-G-3.1 and GS-G-3.5 and elaborates on how ageing management is considered in the process of planning for decommissioning, maintenance, periodic testing and inspections.

SSG-37

This Guide will cover instrumentation and control systems and software important to safety for research reactors and provide recommendations and guidance mainly related to implementing Requirements 10, 16, 17, 24, 25, 26, 27, 28, 29, 31, 35, 37, 39, 41, 49, 50, 51, 52, 53, 54, 55, 71, 75, 77, 86, 87 and 90 of SSR-3.

The changes further include the format standardisation and improves guidance on treatment of design extension conditions in the design of instrumentation and control systems.

How to make a comment

ARPANSA will compile all comments prior to providing the national input to the IAEA. Please use the comment templates for individual Guides provided to have your say. You may use the online webform available below or submit the comment template(s) via e-mail to stakeholdercommentatarpansa.gov.au

Comments will be accepted until 31 May 2020. 

View draft documents on the IAEA website:

Download draft template for comments (please ensure you use the correct template for each Guide):

Participate

Start
28 Apr 2020 - 15:00
End
31 May 2020 - 17:00
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