Regulatory Guide - Siting of controlled facilities (ARPANSA-GDE-1756WEB)
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Applicants should use the nuclear installation or prescribed radiation facility application form depending on the type of facility:
- Licence application form – nuclear installation
- Licence application form – prescribed radiation facility (PRF)
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.
CEO of ARPANSA
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).
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).
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.
- effective control
- safety management
- radiation protection
- radioactive waste management
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.
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.
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.
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.
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.
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
- erosion processes
- subsidence and collapse due to underground features
- soil types and depths
- rock types:
- load bearing capacity
- presence of fracturing
- 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).
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.
This includes information and details related to:
- vegetation types and abundance
- threatened and endangered species.
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).
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).
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);
- 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.
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.
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;
- 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).
5.3.4 Impact assessment - routine operating conditions
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.
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.
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).
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).
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.
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).
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.
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.
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.
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.
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).
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.
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.
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.
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.
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 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’ is defined as an animal or plant living within its natural environment.
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