Conclusions

Within the framework of union agreements, work has begun on the harmonization of technical regulations and uniform requirements for the international transportation of radioactive substances and the

certification of food products and consumer goods. For example, within the framework of the Company

“Atom-CIS”, since 2018, work has been carried out in the group “Implementation of the Agreement on Informational Interaction between the CIS Member States in Moving Radioactive Sources”. The product of this work is the draft document “Uniform procedure and forms for exchanging information on the

movement of radioactive sources”, which is currently being finalized in the participating countries.

In collaboration with the Government of the USA measures are planned for the design and assessment of physical protection systems in order to ensure radiation safety in the framework of the implementation of the Law “On joining the Convention on the Physical Protection of Nuclear Material” dated July 14, 2015 No. 155 [45]. Kyrgyzstan is also collaborating with multiple international organizations in the field of radiation security. International bilateral technical and regulatory cooperation play a significant role in a broad effort to address security concerns and ensuring customs control to prevent illicit trafficking in nuclear materials.

fire safety, and radiation safety supervision does not cover all the requirements of the IAEA GSR Part 3 [14].

In the country, many different SIR are used in medicine and industry. Activities related to the use or management of ionizing radiation sources, including storage, transportation within the country, transfer to another user, and disposal are not licensed: the concept of “authorization” does not currently exist in the existing legislative framework. Furthermore, the control and supervision of SIR handling is not carried out at the appropriate level, since the supervision and control bodies lack appropriately qualified personnel.

Due to gaps in the regulatory framework and regulatory system in the field of nuclear and radiation safety, supplies of SIR and equipment to the NCO, planned as part of technical cooperation with the IAEA, may be stopped.

In addition to SIR, activities relating to the handling of radioactive materials and RW are not licensed and supervision and control over activities are not carried out. This is due to the lack of key functions of the regulatory body, as well as the incomplete legislative basis in the Republic. A lack of qualified staff and the current structure of the regulatory authorities also prevents full inspections of activities related to the handling of radioactive materials, SIR and RW. As a result, operators do not fully meet their responsibilities with regard to ensuring radiation safety. Furthermore, due to the lack of relevant requirements in the current legislation, the Personnel Protection Optimization Program and Safety Assessment are not implemented in organizations, safety instructions are not followed, and individual monitoring is not fully implemented.

Table 6. International Projects with Government of the Kyrgyz Republic as Beneficiary for 2018–2021

No. Project title Donor Recipient Performance

period

1. Nuclear Medicine Recovery KIG6007

IAEA Ministry of Health of the Kyrgyz Republic

2018-2019

2. Strengthening the capacity of radiological laboratories of the sanitary-epidemiological service of the Ministry of Health of the Kyrgyz Republic

KIG7004

IAEA Ministry of Health of the Kyrgyz Republic

2018-2021

3 Improving the system for monitoring and controlling the locations of legacy uranium in accordance with

international safety standards KIG9007

IAEA MES 2018-2021

4 Improving regulatory infrastructure in the field of nuclear and radiation safety in the Kyrgyz Republic

KIG9006

IAEA SIST, DDPSSES MoH KR, SAEP&F

2018-2021

5 European Union project under the Instrument for Cooperation in Nuclear Safety INSC 4.01 / 11-12

“Conducting a Comprehensive Environmental Impact Assessment and Feasibility Study for the Management and Remediation of the Former Min-Kush and Shekaftar

EU MES 2017-2019

No. Project title Donor Recipient Performance period

Uranium Mines in the Kyrgyz Republic” EuropeAid / 135725 / DH / SER / KG.

6 EU project "Management and remediation of high-risk uranium legacy sites in Central Asia (Mailuu-Suu)",

“Conducting a Comprehensive Environmental Impact Assessment and Feasibility Study for the Management and Remediation of the Mailuu-Suu Former Uranium Mines in the Kyrgyz Republic” EuropeAid / 135725 / DH / SER / KG.

EU MES 2017-2019

7 Interstate Target Program "Reclamation of the territories of the EurAsEC member states affected by uranium mining".

RF MES 2017-2023

The radioecological monitoring system in the country is not efficient. Monitoring is distributed between individual departments that cannot carry out the full amount of work for an objective assessment of the state of radioactive contamination. Also, operators do not monitor environmental objects to objectively assess the state of the level of radioactive contamination. Furthermore, Kyrgyzstan does not currently carry out an assessment of radioecological safety for natural objects and natural resources (e.g. coal) with a high content of naturally occurring radionuclides.

Due to a lack of relevant legislation and regulatory requirements, the country still does not have a radon monitoring program, accounting for radon inhalation in residential and public buildings, in workplaces and in hospitals and sanatoriums where radon waters are used for treatment. No measurements of radon escalation are made when choosing sites for the construction of residential and public buildings and structures. Similarly, no radon escalation measurements are made in buildings after their construction.

A “Strategic Master Plan for Restoring the Environment at Uranium Heritage Sites in Central Asia” was approved in 2017 by the order of the Government of the Kyrgyz Republic No. 406-r dated September 18, 2017, which provides for the restoration of uranium heritage objects at the following sites: Kaji-Sai, Mailuu-Suu, Min-Kush and Shekaftar. However, the assistance provided by the European Union within the

framework of the Strategic Master Plan for the remediation of uranium heritage sites is at risk of being curtailed as a result of ongoing gaps in the regulatory framework and regulatory system in the field of nuclear and radiation safety in Kyrgyzstan.

The physical protection of SIR by law enforcement agencies is also not fully provided. Currently, law enforcement agencies do not have the ability to quickly respond to emergency situations related to SIR, since there is no departmental protection of facilities using SIR, or this protection is unnecessarily commercial in nature. As such, ensuring physical protection is difficult for enterprises, who are in an economic crisis, and for state organizations with a small budget. Thus, there is an imperfect system of interaction between the Ministry of Internal Affairs, state bodies and organizations.

4.10.2 Plans for continued cooperation and activities to address regulatory threats

Based on the amendments to the existing laws, work will begin on updating the Priority Action Plan in the field of radiation safety in the Kyrgyz Republic and the development of new strategic programs. A number

of international collaboration projects have been undertaken since 2018 (see Table 6), some of which are ongoing. A Country Cooperation Program has been signed with the IAEA for the period 2018-2023, the coordination of the implementation of which, according to Government Order No. 316-r of September 12, 2018 [41], is entrusted to the SAEPF. Within the framework of this Country Cooperation Program, the position of the Kyrgyz Republic with regard to future technical cooperation with the IAEA, results achieved in completed tasks, as well as the status of implementation of ongoing projects was discussed. Further development and improvement of the legal and regulatory framework on radiation safety, RW management and decommissioning is required to meet the latest international recommendations and the commitments linked to international agreements. There is also a need to a define a national policy and strategy for remediation and the safe management of RW.

Within the framework of its obligations, the Kyrgyz Republic intends to ratify and approve the following conventions and treaties:

 Agreement on privileges and immunities of the IAEA

 Vienna Convention on Civil Liability for Nuclear Damage

 Convention on Early Warning of a Nuclear Accident

 Convention on Assistance in the Case of a Nuclear Accident or Radiation Emergency

 Protocol on small quantities to the Agreement between the Kyrgyz Republic and the IAEA on the application of safeguards in connection with the Treaty on the Non-Proliferation of Nuclear Weapons;

and

 Harmonization of Kyrgyz legislation with the requirements of the IAEA safety standards.

Changes and additions will soon be made to the regulatory enactments in the field of nuclear and radiation safety such that the regulatory body will have all the necessary powers of a regulator. As part of the development of cooperation with the DSA project, a Roadmap for future regulatory cooperation for 2020-2025 has been developed (see Appendix 3).