2.8.2 Safety of Nuclear Installations
Considering regulation of the activities of such large and diversified enterprises as the JSC NAC
“Kazatomprom”, NNC RK and RSE INP, it can be concluded that the existing safety infrastructure is sufficiently effective to protect personnel and the public in the operation of current nuclear facilities. The regulation of activities of a significant number of other enterprises and organizations operating in various areas of atomic energy use also supports this. Nevertheless, there is currently a problem with regulator inspections at nuclear installations, because of the turnover of CAESC staff and the inexperience of newer young personnel working as inspectors.
One proposed measure to resolve the situation of insufficient staff qualifications is to develop “Guidelines for conducting inspections of nuclear and radiation hazardous facilities”. CAESC currently has a regulatory document “System of risks estimations”, which is a formal checklist of items to be reviewed and assessed.
It does not have any specific features for different types of nuclear and radiation facilities. The document, proposed for development in collaboration with DSA, will eliminate this regulatory gap and assist in carrying out inspections of Kazakhstan nuclear and radiation facilities at a higher safety-oriented level.
A very important task for updating regulations to reflect recent changes in the Law on Atomic energy use [3] is the review of Technical Regulation for Nuclear and Radiation Safety [5]. Some items, related to accounting, control and reporting of radioactive waste, should be amended, and the whole document should be reviewed and edited.
During the process of review of the NPP FS MS document and its discussion with invited foreign experts, it was found out that there are possible regulatory threats as a result of some gaps or deficiencies in
regulatory items and procedures. For example, documents on the rules for site selection and requirements for SAR for NPP construction are required. The most important and urgent document may be the one related to site selection. If the decision to start NPP FS development is made, it will be necessary to develop and issue this document. All these documents have been proposed for collaborative development with DSA in the section on Safety of Existing Nuclear Installations. It is intended to develop site selection rules/guidance and guidelines for safety case and safety assessment report content documents in a general form that will be applicable for any type of nuclear or radiation facility, including RW disposal site construction.
2.8.3 Radioactive Material Transport
Transport regulations have been updated and developed over the last decade to meet the requirements for SNF transportation and the transportation of RW and sealed radioactive sources. Nevertheless, because of some obscurities in the functions of state bodies, existing regulations should be updated.
Furthermore, CAESC considers that it is necessary to develop joint rules for the transportation of nuclear and radioactive materials (including RW) with the general approach to physical protection and emergency response.
2.8.4 Emergency Preparedness and Response
At present the legislative and regulatory framework on EPR includes appropriate provisions provided by the Law on Civil Protection [2], the Law on Atomic Energy Use [6] and the National Plan on Response for the Nuclear and Radiation Accidents [14]. Other regulations used during emergency response are
departmental regulations of the Committee on Emergency, the Ministry of Health, the Ministry of Internal Affairs, and the Ministry of Industry and Infrastructure Development. However, CAESC needs to develop a
joint interdepartmental document on interactions between all interested parties involved in the EPR process in accordance with IAEA Safety Standards.
A gap in the EPR system in Kazakhstan is the special training of physicians and other medical personnel for work in the case of a nuclear emergency or radiation accident, as well as special training for general purpose emergency response teams in case of a radiation accident. The program of appropriate training should be developed on the basis of IAEA recommendations.
2.8.5 Radioactive Waste Management, Decommissioning and Remediation
Currently, the Republic of Kazakhstan is actively working on processing the existing Environmental Code and the adoption of a new version of Code. At the same time, the process of consideration and adoption of the draft new Law on RW Management has been slow and difficult and is currently suspended. In this regard, the NTSC, in collaboration with DSA, has prepared proposals for amending the draft Environmental Code to incorporate the most important provisions from the draft Law on RW Management. If the
Environmental Code, the adoption of which is most likely since the process is under the control of the Office of the President of the Republic of Kazakhstan, fully incorporates the proposals for RW
management, then these provisions may be excluded from the draft Law on RW Management. Provisions of the draft Law on RW Management can then be issued in the form of separate normative acts (rules, instructions), approved by orders of the respective ministries.
Orphan sources, i.e. sealed radioactive sources which are out of regulatory control, are a remaining threat in Kazakhstan. A search and secure strategy have been developed for sealed orphan sources and search activities were carried out between 2012-2013 at some abandoned sites. Orphan sources discovered during the survey were returned under regulatory control. The program was funded at that time by the US
Department of Energy (US DOE) through the Unites States National Nuclear Security Administration (US NNSA), but is not currently funded, which is considered a threat. The program needs some updating and it is necessary to continue the physical search for orphan sources.
The handling of radioactive scrap metal is also an issue in the Republic of Kazakhstan. The processing of scrap metal can lead to irradiation of personnel of transport companies, collection sites, smelters, and the possibility of subsequent contact with metal products, followed by exposure of the population. For example, there are known cases in the world where scrap metal was used to produce building
reinforcements, leading to increased doses to building residents. To address this problem, it is necessary to:
Develop a procedure for scrap metal handling, including appropriate monitoring of enterprises working with scrap metal, as well as importing/exporting scrap metal
Conduct training seminars for all categories of personnel working with scrap metal to familiarize with signs of radiation hazard and typical containers, detection and safe handling of detected sources
Work with the largest scrap metal processing enterprises, to check availability and/or convince them of the need to purchase and install radiation monitoring equipment.
Even though the problem of radioactive scrap metal handling needs to be resolved, it is not currently clear what kind of special document should be developed. However, some provisions of requirements for radioactive scrap metal handling may be included in the general documents for RW management.
As for SNF, a decision has not yet been made as to whether SNF is a valuable resource or waste. SNF management is represented currently by long-term storage under surveillance at specialized storage sites, in compliance with government decisions in this area.
The absence of a final management strategy for SNF may be considered as one of the main threats for future SNF management and for new NPP construction decision making. Some developed countries have special laws on SNF management but, with relatively low amounts of research reactor SNF and with a temporary storage solution for BN-350 SNF, a final solution is not urgent. Nonetheless, taking into account the long-term procedures for decisions and their approval in this area, plans should be made over the next few years. In the absence of regulatory documents on SNF strategy in Kazakhstan, the provisions for SNF management and safety should be included into a law or rules document for the government position on this subject to be accepted and approved.
In order to eliminate remaining regulatory gaps in RW management, it is proposed to develop and to approve the following documents:
Update existing document “Rules of collection, storage and disposal of radioactive waste” [20] and to split it into two separate documents: 1) Rules of SNF storage and 2) update of RW management provisions considering provisions of RW related documents, developed in collaboration with DSA.
Guidelines to create an effective mechanism of RW management funding in Kazakhstan.
Methodical guide for remediation of nuclear testing sites.
Guidelines for RW acceptance for long-term storage.
In order to give more guidance for operators involved in the decommissioning process, it is also proposed to develop the document “Guidelines for the decontamination of premises, equipment and materials”.
As identified above with regard to remediation of legacy sites, current gaps in the regulations for remediation works may represent a potential threat. Experience over the last few years on the initiated works for nuclear sites and contaminated areas remediation, has shown that development of regulatory documents is required to address remaining safety issues in these regulatory areas. To resolve the problem, it will be necessary to develop a program on elaboration of the following new regulations in cooperation with the MEGNR, the Ministry of Health and CAESC:
Guidelines to establish criteria and requirements for remediation of uranium legacy sites; and
Rules for licensing of activity within programs of uranium mines remediation.
2.8.6 Radiation and Nuclear Security
Recently, Kazakhstan developed and accepted several regulatory documents related to physical
protection (nuclear security), but issues remain. One of the identified issues is the absence of regulations for physical protection of sealed sources during transportation and the procedure to include them into the transport regulation is ongoing. Meanwhile CAESC is developing the document “Methodical
Recommendations for Physical Protection of Ionizing Radiation Sources during Transportation”.
The development of regulations for physical protection in the area of atomic energy use (nuclear security) in Kazakhstan is currently being supported by the US National Nuclear Security Administration (US NNSA).