3 Regulatory framework for Nuclear and Radiation Safety in Tajikistan
3.8 Main identified threats and proposals for their elimination
This section contains a list of threats and challenges that currently exist and adversely affect nuclear and radiation safety in Tajikistan and the activities of NRSA as the central executive body for state regulation of nuclear and radiation safety. Measures to address the threats and challenges are set out in a
‘Roadmap’, detailed in Appendix 2.
3.8.1 Organization and general principles of the regulatory body (including physical protection)
Currently, the Law “On Use of Atomic Energy” [2] describes activities and facilities which are under state regulation and identifies general requirements for them. Unfortunately, it does not describe a full lifecycle approach to activities belonging to nuclear and radiological facilities, including research reactors. As a result, there are lot of uncertainties associated with activities for both operators and the regulatory body.
The Law “On licensing of separate types of activities” [9] includes activities associated with “use of atomic energy” and “radioactive waste management”, similarly fails to consider all activities associated with nuclear and radiological facilities in a full lifecycle approach. As such, the regulatory body does not have the appropriate rights to regulate the full lifecycle of facilities.
There is a general law on inspection in Tajikistan, namely the Law “On Inspection of business entities”
[8]. It identifies and describes all provisions related to inspection. In 2014 there was an amendment to the law which listed inspection bodies with the right to carry out inspections in Tajikistan. NRSA, along with other regulatory bodies, was not included on the list of inspection bodies. As a result, NRSA has only limited rights to carry out inspections. These rights are restricted to only pre-licensing
inspections and inspections in the case of accidents or emergency situations. Therefore, most facilities with nuclear materials and high activity radioactive sources are not currently subject to inspection.
The new Law “On Legal and regulatory documents” identifies the ministries and organizations that have rights to develop regulatory documents. Currently the NRSA is not included, which makes the development of new regulations in the field of radiation safety and nuclear security difficult.
NRSA is in the system of Academy of Sciences. However, the Academy of Sciences does not hold any regulatory function, such as inspection, licensing and enforcement, under Tajikistan legislation, but the NRSA does have the competency and rights as the national regulatory body. This situation creates difficulties for the process of high-level decision making.
Decree of Government of the Republic of Tajikistan “On regulation on licensing specifics of separate kinds of activities” [11] does not include a list of necessary documents for applying for a license on activities related to RWM (including remediation activities) and the full lifecycle of nuclear facilities.
This causes difficulties with the licensing process for these activities.
Decree of Government of the Republic of Tajikistan “On state regulation in the field of ensuring radiation safety” describes the functions, responsibilities and rights of the regulatory body and its inspectors. This document was developed in 2004. It does not fully cover all aspects of the functions and responsibilities of the regulatory body and, as a result, NRSA does not have all required
competencies for regulation.
There is currently no procedure in place describing how project documentation submitted for the issuance of licenses for remediation activities related to territories contaminated by uranium
production should be evaluated and local experts do not have experience in this field. As such, there are difficulties associated with issuing licenses.
There is no procedure on how to carry out inspection activities related to the remediation of territories contaminated by uranium production and local experts lack experience in this field, giving rise to difficulties in carrying out inspections.
The TSO to NRSA has a building with limited territories, rooms, and capacity for carrying out monitoring. Additional space and capacity are required to support monitoring during remediation activities and analysis of samples.
There is no single Information System supporting functioning of the regulatory body. Separate databases are used that are not harmonized which causes difficulties when undertaking regulatory functions such as analyzing the current situation or planning inspections.
The NRSA as an organization does not have Quality Management Accreditation which makes it difficult to check the quality of the system and provided services.
Currently, to apply for a license, applicants are required to collect required documents from different organizations and places. To make it easier for applicants, the Government of Tajikistan has started an initiative to establish a “single window” system where applicants can collect and submit documents in one place or through a web portal. The NRSA is not yet in a position to establish such a system.
New staff at the NRSA and its TSO lack experience in regulatory functions.
There is no building for the north branch of the NRSA which greatly impacts its regulatory functions such as licensing, inspection and enforcement measures. During remediation works at uranium legacy sites NRSA staff currently reside temporarily at the operators’ site, which creates a conflict of interest.
Tajikistan authorities have not yet undertaken a threat assessment and categorization of facilities/practices in accordance with the five threat categories of GSR Part 7 [15].
3.8.2 Safety of Nuclear Installations
The Law “On Use of Atomic Energy” [2] describes activities and facilities which are under state regulation and identifies general requirements for them but does not describe the full lifecycle of activities relating to nuclear and radiological facilities. As a result, there are lot of uncertainties associated with activities for both operators and the regulatory body.
Currently, the draft law “On Licensing of Individual Types of Activity" is in the parliament for approval and will stipulate the licensing of activities for the whole lifecycle of the research reactor (including site selection, feasibility study, planning, construction, commissioning, operation, and
decommissioning). After approval by parliament, NRSA will be required to develop new documents and requirements related to the process of licensing activities related to each element of the research reactor’s lifetime. Since this area is new for NRSA, international assistance and support is needed to develop the regulations according to IAEA recommendations and international best practice.
There is currently a lack of inspectors and experts in the field of research reactors in the country.
3.8.3 Radioactive Material Transport
In Tajikistan there are a limited number of transport and storage companies that can transport or store radioactive materials. Establishing a protected building for storing radioactive sources and
procuring specialized transport vehicles requires high-level qualifications and funds. As a result, many transport and storage companies do not want to work with radioactive materials.
Only limited courses are organized to provide appropriate training on radiation protection to transport and storage companies in the country.
3.8.4 Radiation Safety
Currently, article 17 of the Law “On Radiation Safety” [1] requires individual doses received by citizens to be controlled and accounting for, but no rules have yet been developed.
There is only a general requirement for radiation protection in medicine. Specific requirements are required for nuclear medicine and teletherapy in order to ensure radiation protection.
A national database, held and maintained by NRSA, is required to record information on workers throughout the country that are working with sources of ionizing radiation and the doses they receive.
Equipment used by the TSO to NRSA for radiation dose monitoring of personnel working with sources of ionizing radiation is old and often in need of repair. Capacity is also limited. There is also no internal dosimetry service in the country. Therefore, internal dosimetry services are not provided to workers that may be occupationally exposed as a result of practices using unsealed sources in medical and other applications.
Diagnostic Reference Levels (DRL) for medical exposure have not been established in Tajikistan, which are needed for the control and optimization of patient exposures.
A national database of doses received by patients as a result of medical examinations is also required to allow medical exposures to be reviewed.
No program has yet been approved by the Ministry of Health to upgrade old fluoroscopic units and other X-ray equipment.
In computed tomography, special low dose protocols haven't been introduced.
There are no companies in Tajikistan for the maintenance and servicing of nuclear medicine and radiotherapy equipment.
Legislation is in place requiring patient doses to be measured, but not all hospitals have the necessary infrastructure to follow this legislation.
Only limited measurements have been carried out on the impact of radon on the population so the situation throughout the country is not clear. Furthermore, requirements on radon in national legislation are not consistent with IAEA GSR Part 3 [10].
There is growth nationally in the construction of new buildings. Construction materials from different natural sources can contain high concentrations of natural radionuclides that can impact public exposure. Requirements on use of construction materials in legislation are not consistent with IAEA GSR Part 3 [10].
There is no national plan or program in the country for environmental monitoring to establish the radiation background situation and identify any natural radiation hot spots in the country.
Not all border crossing points in Tajikistan are equipped with portal monitors to detect radiation sources.
Facilities using sources of radioactive sources are required to have in place physical protection plans.
An example plan has been developed based on the requirements, but it is necessary to help facilities develop their own plans.
In the Law “On Use of Atomic Energy” [2] there is a requirement for the education of the personnel working with ionizing radiation sources, but there is no clear requirement for professionally recognized qualifications, e.g. RPO, medical physicist and qualified expert.
There is no national register of how many personnel are working with ionizing radiation sources or of their qualifications and training needs. Training syllabuses are available only in some areas of radiation protection but, in the absence of a register of training requirements, it is not clear what further training courses for personnel should be organized.
A National program for training and education in the field of radiation protection has been developed, but an action plan on how to implement it is needed.
There are only limited courses organized nationally for RPOs, medical staff on radiation protection and medical exposures, staff of stations responsible for monitoring the radiation situation throughout the country, and users of radioactive sources in the country on radiation safety and security.
Similarly, there are only limited courses and informative events organizing for the population on radiation safety in the country.
The NRSA regional training center on radiation protection is functioning, but there are not enough instructors to conduct training.
3.8.5 Emergency Preparedness and Response
Tajikistan authorities have not yet undertaken a threat assessment and categorization of facilities/practices in accordance with the five threat categories of GSR Part 7 [15].
Formal procedures for record-keeping and controlling doses received by the emergency workers have not been established.
The National Safety Standards (NRB-06) [3] established default operational intervention levels (OILs) of dose for acute exposure by organs or tissues and generic action levels for foodstuffs. However, these levels are not consistent with those given in GSR Part 3 [10] and GSR part 7 [15].
No specialist services or procedures for medical responses to radiological emergencies are in place.
There are no procedures in place on the management of radioactive waste arising from the implementation of agricultural countermeasures.
There is no automated 24-hour radiation monitoring network to measure dose rates across the territory and transmit data to the central station. Only a few stations across the territory have equipment to measure radiation background dose rates and measurements must be made manually.
There is a requirement for internal emergency response plans to be in place for facilities using radioactive sources. However, facility operators lack the knowledge and skills to develop emergency response plans themselves.
There is a general requirement for first responders to respond to nuclear and radiological accidents, but there is no guidance on how they should respond to emergencies.
Only limited courses are organized for first responders on responding to radiological accidents in the country and no joint training exercises have been organized for the different first responders involved in responding to nuclear and radiological accidents.
The National Plan (Program) on EPR (Approved by Government on 2013 #770), in compliance with IAEA standards, was finished in 2018 and currently via IAEA TC, a national Project Crisis Center on
responding to nuclear and radiological accidents in the country is establishing with the CES CD playing a leading role.
There is a requirement to keep the public informed about any emergency situation in the country but, at present, information being presented on this subject is not sufficient.
3.8.6 Radioactive Waste Management, Decommissioning and Remediation
Currently the Law “On Radioactive waste management” [7] and the “Rules on Radioactive waste management” [20] identify requirements for RWM and the roles and responsibilities of operators, but these are not in compliance with IAEA GSR Part 3 [10], GSR Part 5 [26] or GSR Part 6 [27], leading to difficulties in implementing radiation safety requirements during RWM.
No safety assessment has been undertaken of the RWDS to understand the main risks and threats.
The RWDS has limited capacity for long term storage of RW. Urgent action is required to address issues with the storage of liquid RW to prevent release to the environment.
Only limited courses are available around radiation safety and RWM for operators.
Currently in Tajikistan, specialized organizations for RWM, such as RWDS, and operators of uranium legacy sites, as well as the TSO to NRSA have limited equipment for carrying out workplace monitoring and environmental monitoring. This leads to difficulties in analyzing the current radiological situation in facilities and at legacy sites.
There are limited staff in NRSA with the necessary experience and expertise to inspect remediation activities and projects.
The Law “On Radioactive waste management” [7] required a State Registry of radioactive waste storage facilities and radioactive wastes to be established and operated by NRSA, with NRSA requesting operators to provide the necessary information. However, no tool has yet been developed to support and operate such a registry. Furthermore, there is currently no database for collecting and analyzing information regarding uranium legacy sites in the country, such as environmental monitoring data for these sites.
Some uranium legacy sites have been studied and environmental impact assessment and feasibility studies prepared for further remediation actions [28]. Other sites require assessments to be undertaken to evaluate risks and to develop remediation plans.
Currently, the Taboshar, Degmay, Chkalovsk and Gafurov uranium legacy sites are in a bad radiological situation and urgent remediation actions are needed.
Currently, the TSO to NRSA has a building with limited territories, rooms, and capacity. Additional space and capacity are required to carry out monitoring during remediation activities and to analyze monitoring samples.
Another important limitation for carrying out remediation activities is a lack of appropriate infrastructure. In this regard NRSA is faced with a number of problems and tasks to be solved, including: development of the legislative basis for remediation of former uranium industry sites;
assessment of radiological consequences of uranium industry sites; assessment of the condition of remediation controls; compliance analysis to determine the extent to which international standards and recommendations have been fulfilled; development of an action plan to minimize the impact of uranium industry sites on the environment; and, procurement of analytical equipment for monitoring sites. These documents and activities should take account of IAEA recommendations [17, 29-36] as incorporated, or due to be incorporated, in the Tajik legal framework.
Criteria to regulate radioactive discharges require further development, in line with IAEA recommendations.