30. The inspections of storage conditions shall be planned, organised and conducted with the periodicity established by the Service regulatory guides after receipt of the first RTG batch for storage, throughout the entire period of temporary storage.
31. Unplanned inspections of storage conditions can also be conducted.
submit them for approval to the territorial authorities of the Service. The above enterprises should arrange training of the personnel that will take part in transportation operations in the course of decommissioning activities.
3.2. Quality assurance and radiation protection programs
35. The programs of quality assurance and radiation protection shall be developed and approved at the initial stage of decommissioning activities (Appendix № 2).
The quality assurance programs shall be developed by all the organisations listed in Table № 1.
The radiation protection program shall be developed by the operating organisations and the organisations that exercise the RTG (RHS) temporary storage.
36. The quality assurance program is aimed to assure the organisation administration that the system of safe operations in the FUAE (decommissioning activity) corresponds to the standard requirements.
37. The quality assurance program shall:
а) establish the goals and purpose of the program;
b) determine the policy of the organisation in the sphere of quality assurance;
c) mark the limits of responsibility for quality assurance between the organisations performing operations and those rendering services;
d) define the list of the documents containing standard requirements to quality assurance and determine their hierarchic structure;
e) mark the limits of responsibility for quality assurance between the officials and the services of the organisation;
f) analyse the management structure of the organisation as far as the effective quality assurance is concerned;
g) provide the list of principal undertakings for quality assurance and characterise their interrelation;
h) establish the internal system of control of non-compliances and define the control procedure.
38. The radiation protection program shall include:
а) goals and purpose of the program;
b) principles, documents and technical facilities ensuring radiation protection in the course of the work performance;
c) the measures ensuring radiation protection of personnel and population in the course of the work;
d) the list of regulatory documents on radiation protection assurance and its hierarchic structure;
e) principal undertakings on radiation protection and their interrelation;
f) organisation and procedure of implementation of the internal system of control of discrepancies in the course of radiation protection activity.
3.3. RTG decommissioning program
39. Before starting the work on decommissioning, the operating organisation shall undertake to collect and analyse the retrospective data on the history of operation of each RTG (group of RTG), included in the list. The above analysis and other materials shall be used as a basis for the development and approval of the decommissioning program which should contain the following information:
а) decommissioning activities schedule;
b) general information on the RTG dismantling process, transportation schemes of evacuation of the radiation packages with the RTG;
c) the branches or separate subdivisions of the operating organisation involved in the work and the types of the work they perform;
d) quantity and qualification level of the personnel involved in the work;
e) the prognosis of the collective effective radiation doze which the personnel will be exposed to in the course of the work performance;
f) organisation and methodology of inspection of the radiation packages with RTG (RHS) at the sites of their location;
g) the list of organisations conducting the work and rendering services during decommissioning activities;
h) tentative list of RTG field inspection commission members in the locations of operation, procedure for decision-making on possible (impossible) continuation of the work on decommissioning;
i) procedure of emergency response measures planning and realisation, communication scheme for transmission of the established form of messages concerning the violations occurring in the course of the work, the interaction of emergency response units;
j) composition, time period and procedure for RTG decommissioning deliverables.
40. The program should establish the following general requirements:
а) to the methodology of radiation and engineering inspection of RTG in the locations of operation, procedure of making and realisation of the decision on possible dismantling and transportation;
b) to the observance of justification and optimisation principles (ALARA) in selection of the methods of RTG dismantling, transportation, including the type of transport and the transportation route for each group of the RTG operated in similar conditions;
c) to the procedure for evaluation of the impact from hazardous natural and technogenic (man-induced) factors to safety during decommissioning work;
d) to the system of measures for prevention of accidents and elimination of the consequences thereof.
41. The program should define the requirements for physical protection system at all the stages of RTG decommissioning, temporal and spatial boundaries and limits of responsibility for safety assurance of the organisations involved in conducting particular stages of the work, on contractual basis.
3.4. RTG decommissioning project
42. The RTG decommissioning project is developed on the basis of decommissioning program. The Project shall be agreed on with RTG designer and approved by the federal executive body which the operating organisation is subordinated to.
43. The Project is required to have sanitary and epidemiological finding by federal executive body authorised to state sanitary and epidemiological supervision or by authorised territorial representation of the above body of the subject (subjects) of the Russian Federation, where the activities are planned.
44. The project, as a rule, consists of the main part justifying general requirements to the administrative, engineering and sanitary and epidemiological measures on RTG decommissioning and a special part defining safety requirements at separate stages of the work.
45. The projects shall not envisage RTG partial disassembly in the course of the work on dismantling and evacuation.
46. It is allowed to make separate projects for:
а) the work on RTG inspection and dismantling from locations of operation, as well as on delivery to the organisation exercising temporary storage;
b) The RTG delivery from the locations of temporary storage to FSUE “PA “Mayak” for long-term storage and disposal.
47. The list of initiating events, analysis of design basis accident consequences is made on the basis of the conservative approach.
48. It is appropriate that the project provides for a stock of reserve shielding containers and the method of their delivery to the RTG operation locations, as well as for the process of operations for replacement of shielding containers in field condition for each RTG type.
49. The project shall contain:
а) the data on geographical, climatic and geo-morphological peculiarities of the RTG location in the locations of operation;
b) the data on hazardous natural and technogenic (man-induced) factors which may have impact on the decommissioned products in the course of decommissioning activities;
c) general information on the RTG operation background, including the data on current radioactivity of strontium-90 radionuclide in the RHS making up a set with the RTG;
d) retrospective data of radiation monitoring;
e) justification of the necessity to formalise permit-certificates including the permit-certificates for transportation under special conditions;
f) justification of the efficiency and safety of process flow sheets used for RTG dismantling from operation sites, including replacement of inadequate shielding containers, selected types of transport an transportation routes;
g) radiation monitoring methodologies and technical facilities including those used in the design basis accident conditions;
h) justification of the measuring instruments planned to be used;
i) potential initiating events and analysis of the evolution of potential radiation accidents followed by assessment of the consequences thereof and prognosis of radiation situation;
j) material support of emergency response measures;
k) justification of the most safe transportation scheme for delivery of the RTH (RHS) radiation packages to specialised organisations exercising their temporary and long-term storage;
l) measures for organisation and upkeep of the RTG (RHS) physical protection system in the course of decommissioning activities;
m) safety measures during RTG transportation, including emergency response measures;
n) justification of the RTG radiation and engineering characteristics assessment methodologies.
3.5. Safety justification report
50. The decommissioning project serves as a basis for the operating organisation to develop a report of justification of safe RTG decommissioning. No later than one month before the start of the field stage of work the report shall be submitted for approbation to the Service territorial authority exercising state supervision over the activity in the FUAE in the corresponding subject of the Russian Federation.
51. If a large number of the RTGs operated in different environmental conditions is involved in the decommissioning process, safety justification reports shall be made for each area where operations are carried out .
52. The report shall contain:
а) general information about the operating organisation;
b) general information about the area where the work is planned;
c) RTG (RHS) technical characteristics;
d) summarised design safety requirements;
e) analysis of the retrospective data accumulated in the process of operation for each RTG planned to be decommissioned;
f) list of mandatory requirements to be met during the work, including those set forth in НП-053-04, section 1.2 «Basic provisions on safety assurance in transportation”.
53. The report shall justify the observance of radiation safety principles and regulatory requirements at all the stages of decommissioning activities, specified in para. 7 of the Methodology, except for sub-paragraph 7-e.
IV. PRE-INSPECTION PREPARATORY ACTIVITIES 4.1. Documents subject to be reviewed
54. Prior to the inspection, the Service official (officials) shall review the regulatory documents that establish safety requirements during such inspections:
a) federal and departmental regulatory documents that regulate the activity of organisations in the FUAE (Appendix № 1);
b) permission documents entitling the organisation to perform decommissioning activity and specifying the terms of its performance;
c) inspected organisation inspections background by the materials of previous inspections;
d) administrative and regulatory documentation regulating safety measures during the work;
e) technical documentation representing the RTG (RHS) radiation and engineering characteristics;
f) operating documents containing information about the peculiarities of the RTG location and operation;
g) deeds (reports) of investigation of the violations of the RTG proper operation;
h) The Service regulatory guide specifying the procedure of inspections of the activity in the FUAE, including the given Methodology.
55. The recommended list of basic regulatory documents subject to be reviewed, as the type of inspection requires, is provided in Table 2.
Table 2 The documents used in the course of state supervision
Types of inspections (Table № 1) Documents to be reviewed tType
1 tType
2 tType
3 tType 4
Legislative deeds and regulatory documents listed in Appendix № 1 + + + + Service regulatory guide specifying the procedure of inspections
activity + – + +
Permission documents issued by authorised state bodies (Service license and permission conditions, sanitary and epidemiological findings on compliance of the work being performed with state sanitary and epidemiological rules and standards)
+ – + +
Available certificates (permit-certificates) for radioactive material of special type, the RTG design as packages of B(U) type, for shipment
(transportation) including shipment under special conditions + – + – Inspection background of the organisation (violations revealed in the
course of inspections, timeliness and completeness of their
elimination) + – + +
Materials of investigation of the violations in the course of RTG
operation + – + +
Documents formalised by the results of the RTG inspection prior to
dismantling + – + –
Quality assurance program + – + +
Radiation protection program + + + –
RTG decommissioning program + + – –
RTG decommissioning project + + – –
Safety justification report + + – –
4.2. Recommendations for regulatory documents review
56. In reviewing the regulatory documents the following aspects should be specifically noted:
а) conformance (difference) of planned operations process to the safety requirements established in the Legislative deeds and regulatory documents;
b) limitations set forth in the Service license and permit conditions, sanitary and epidemiological findings, permits-certificates;
c) availability and content of the insurance contract (insurance policy);
d) justification of the established categories of radiation facilities according to the potential radiation hazard;
e) timeliness and completeness of information on compliance, within prescribed time periods, with the requirements, contained in license terms and conditions;
f) current state of radiation safety in the organisation registered in radiation and sanitary passport (onward – RSP), findings of state sanitary and epidemiological supervision bodies on RSP content;
g) content of radiation and ecological passport of the hazardous radiation facility;
h) information on the radiation situation at the sites of RTG operation, disclosed facts of unauthorised actions with regard to the RTG;
i) information on the system of personnel training and test of knowledge at the organisation, including safety measures during RTG transportation by different kinds of transport;
j) nature and reasons of the violations registered in the course of previous inspections, orders issued for their elimination, and trustworthiness of the information on fulfillment of the orders;
k) information on the measures undertaken by the organisation to prevent radiation accidents and ensure preparedness to eliminate consequences thereof;
l) content of the deeds (reports) on violation investigation of RTG proper operation (if any);
m) information about the inspected radiation hazardous facility (facilities) contained in the operating organisation’s radiation safety analysis reports;
n) materials of emergency response training.
57. It is necessary to become familiar with the general characteristic of the organisation’s activity, as well as with:
а) the peculiarities of decommissioning processes applied, including the types of transport facilities and the peculiarities of their use;
b) operational documentation for main types of equipment, mechanisms and devices used for carrying out the processes (engineering specifications, operational, installation and dismantling instructions, logbooks and passports).
58. Using the data registered in each RTG card, familiarise with its operation background.
59. Review the general safety requirements in carrying out the entire complex of RTG-related works.
60. If the process of decommissioning activities provides for usage of hoisting devices during RTG dismantling and movement, it should be noted that the above operations are falling under the effect of the regulatory document НП-043-03 (see Appendix № 1, para. 6).
4.3. Order of RTG operation background review
61. In the course of preparation for inspection one should get familiar with the results of the analysis carried out by the operating organisation with regard to the information collected during the period of RTG operation. Special attention should be paid to the products located nearby populated sites, especially, if in the course of operation, any unauthorised actions were registered.
If the operating organisation does not have the documentation (complete package or partially) escorting the product to be decommissioned, it is allowed to use other copies of the documents for the given RTG type. In such case the operating organisation drafts and submits the Deed of RTG operational documentation loss.
The analysis of information shall address the following factors:
а) comparison of the values of dose rate generated by RTG, which are measured at the manufacturing plant and during the RTG operation. Special attention should be paid to the products where dose rate increase was noted even if the measured values were within the prescribed limits;
b) estimate of geographical, geo-morphological and climatic characteristics of RTG operation locations (climate, relief, accessibility for unauthorised persons, remoteness from water area, excess, soil etc.) when selecting the decommissioning technology;
c) correct analysis of the hazardous natural events, that may exert impact on the RTG, and the decommissioning process;
d) analysis of RTG technical condition, in particular, notes in logbooks, deeds of shielding container inspection, availability of official reports, notes and memorandums and other evidence of RTG proper operation violations;
e) documentation on the RTG movements from one operational station to another and the reasons for these movements.
62. Analyse the RTG decommissioning program approved by the operating organisation head, paying attention to:
а) administrative an engineering measures, envisaged to ensure the RTG safe decommissioning;
b) quantity and qualification level of the personnel of the operating organisation branches and separate subdivisions, which participate in the work on decommissioning;
c) approved RTG decommissioning action plan and information on the course of its completion.
63. To become familiar with the safety instructions for transportation of hazardous freight class 7 (radioactive substances), developed by the organisations rendering RTG (RHS) transportation services.
The given instructions shall be:
а) adopted to the method of transportation, to radiation and engineering characteristics of the transported freight;
b) agreed on by the territorial body (structural unit of the territorial authority) of the Service which implements state supervision and monitoring at the location of transport organisation.
64. Instructions should allow for the model safety requirements cited in chapter 6 of the present Methodology.
65. Make sure that the air crew and drivers of the transport vehicles used for transportation of radiation packages with RTG (RHS), have the certificates (permits) for hazardous freight class 7 (radioactive substances) transportation, as well as permits for surface transport facilities for transportation of the indicated hazardous freight, drawn up in accordance with the established routine.
V. LIST OF ISSUES SUBJECT TO VERIFICATION