Manual 12676013

Manual 12676013
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE
TO OBLIGATIONS UNDER THE JOINT CONVENTION ON SAFETY OF
SPENT FUEL MANAGEMENT AND ON THE SAFETY OF RADIOACTIVE
WASTE MANAGEMENT
SEPTEMBER 2011
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
i
ACKNOWLEDGEMENT
The South African National Nuclear Regulator (NNR) acknowledges the support and cooperation
of the South African Department of Energy (DoE), South African Department of Health
(Directorate Radiation Control), South African Nuclear Energy Corporation (Necsa), Eskom and
South African mining sector in the preparation of this report.
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
Table of Contents
ACKNOWLEDGEMENT...............................................................................................................................................................................
iii
TABLE OF FIGURES .....................................................................................................................................................................................
iv
EXECUTIVE SUMMARY...............................................................................................................................................................................
1
SECTION A: INTRODUCTION........................................................................................................................................................
2
A-1.
BACKGROUND..........................................................................................................................................................
2
A-2.
PURPOSE....................................................................................................................................................................
3
A-3.
STRUCTURE OF THE REPORT...............................................................................................................................
3
SECTION B: POLICIES AND PRACTICES..................................................................................................................................
5
B-1.
RADIOACTIVE WASTE MANAGEMENT POLICY FRAMEWORK OF SOUTH AFRICA...........................
5
B-2.
RADIOACTIVE WASTE MANAGEMENT PRACTICE........................................................................................
6
B-3.
SPENT FUEL MANAGEMENT POLICY................................................................................................................
7
B-4.
SPENT FUEL MANAGEMENT PRACTICES........................................................................................................
8
B-5.
CRITERIA USED TO DEFINE AND CATEGORISE RADIOACTIVE WASTE..................................................
8
SECTION C: SCOPE OF APPLICATION ....................................................................................................................................
12
C-1.
USED FUEL AND REPROCESSING ....................................................................................................................
12
C-2.
THE SAFETY OF RADIOACTIVE WASTE MANAGEMENT ...........................................................................
13
C-3.
MILITARY OR DEFENCE PROGRAMMES .........................................................................................................
13
C-4.
DISCHARGES ............................................................................................................................................................
14
SECTION D:
LISTS OF FACILITIES AND INVENTORIES ........................................................................................................
15
D-1
LIST OF THE USED FUEL MANAGEMENT FACILITIES .................................................................................
15
D-2
USED FUEL INVENTORIES ...................................................................................................................................
15
D-3
LIST OF THE RADIOACTIVE WASTE MANAGEMENT FACILITIES..............................................................
16
D-4
INVENTORY OF RADIOACTIVE WASTE ............................................................................................................
16
D-5
LIST OF NUCLEAR FACILITIES IN THE PROCESS OF BEING DECOMMISSIONED................................
16
SECTION E: LEGISLATIVE AND REGULATORY SYSTEMS ...................................................................................................
17
E-1
IMPLEMENTING MEASURES ..............................................................................................................................
17
E-2
LEGISLATIVE AND REGULATORY FRAMEWORK ...........................................................................................
17
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
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E-2.1.
LEGISLATIVE FRAMEWORK ................................................................................................................
18
E-2.2.
REGULATORY FRAMEWORK ..............................................................................................................
19
E-2.2.1.
SAFETY REQUIREMENTS AND REGULATIONS FOR RADIATION SAFETY; .........
19
E-2.2.2.
LICENSING OF ACTIVITIES ................................................................................................ 20
E-2.2.3.
PROHIBITION OF THE OPERATION WITHOUT AN AUTHORISATION ..................
22
E-2.2.4.
REGULATORY INSPECTIONS, SAFETY DOCUMENTATION AND REPORTING ...
23
E-2.2.5.
ENFORCEMENT ............................................................................................... .....................
24
E-2.2.6.
ALLOCATION OF RESPONSIBILITIES............................................................................... 24
E-3
THE ESTABLISHMENT OF A REGULATORY BODY ......................................................................................... 25
E-3.1.
NATIONAL NUCLEAR REGULATOR ...................................................................................................
25
E-3.2.
ORGANISATION OF THE NNR ............................................................................................................
26
E-3.3.
INDEPENDENCE OF THE REGULATORY FUNCTION ...................................................................
29
SECTION F:
iv
GENERAL SAFETY PROVISIONS .................................................................................................................
RESPONSIBILITY OF THE LICENCE HOLDER ........................................................................
30
F-1
F-1.1.
RESPONSIBILITY FOR SAFETY .................................................................................
30
F-1.2.
RESPONSIBILITY IN ABSENCE OF NUCLEAR AUTHORISATION HOLDER ..
31
F-2
HUMAN AND FINANCIAL RESOURCES ...................................................................................................
32
F-2.1.
QUALIFIED STAFF ..........................................................................................................................
32
F-2.2.
FINANCIAL RESOURCES ..............................................................................................................
33
F-2.3.
FINANCIAL PROVISION FOR POST-CLOSURE MANAGEMENT OF FACILITIES ...........
34
F-3
QUALITY ASSURANCE ...................................................................................................................................
35
F-3.1.
QUALITY ASSURANCE AT NECSA ............................................................................................
35
F-3.2.
QUALITY ASSURANCE AT ESKOM............................................................................................
37
F-4
OPERATIONAL RADIATION PROTECTION ...............................................................................................
39
F-4.1.
F-4.1.1.
DOSE LIMITS...................................................................................................................
39
F-4.1.2.
ALARA FOR WORKERS AND PUBLIC ......................................................................
42
F-4.1.3.
OCCUPATIONAL DOSE CONTROLS.........................................................................
42
F-4.1.4.
MEASURES TO PREVENT UNPLANNED/UNCONTROLLED RELEASES ........
43
F-4.2.
DISCHARGE CONTROL ................................................................................................................
43
F-4.2.1.
OPERATIONAL RADIATION PROTECTION: LEGAL FRAMEWORK ..................................
30
39
DISCHARGE LIMITS AND REGULATORY REPORTING........................................
44
F-4.3.
UNPLANNED RELEASE OF RADIOACTIVE MATERIALS INTO THE ENVIRONMENT ....................
45
F-5
EMERGENCY PREPAREDNESS .....................................................................................................................
46
F-5.1.
EMERGENCY PLANS.......................................................................................................................
46
F-5.2.
INTERNATIONAL ARRANGEMENTS...........................................................................................
48
F-5.3.
PREPARATION AND TESTING OF EMERGENCY PLANS ......................................................
49
F-6
DECOMMISSIONING.......................................................................................................................................
49
F-6.1.
QUALIFIED STAFF AND ADEQUATE FINANCIAL RESOURCES ........................................
49
F-6.2.
REQUIREMENTS DURING DECOMMISSIONING ..................................................................
50
F-6.3.
DECOMMISSIONING AT KOEBERG ..........................................................................................
50
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
F-6.4.
DECOMMISSIONING AT NECSA: ..............................................................................................
50
F-6.5.
PROVISIONS WITH RESPECT TO EMERGENCY PREPAREDNESS ....................................
51
F-6.6.
RECORDS OF INFORMATION IMPORTANT TO DECOMMISSIONING ...........................
51
SECTION G:
SAFETY OF SPENT FUEL MANAGEMENT ................................................................................................
52
G-1
GENERAL SAFETY REQUIREMENTS ..........................................................................................................
52
G-1.1.
G-1.1.1.
KOEBERG: .......................................................................................................................
52
G-1.1.2.
Necsa:...............................................................................................................................
53
G-1.2.
RADIOACTIVE WASTE MINIMISATION ...................................................................................
54
G-1.3.
INTERDEPENDENCIES IN SPENT FUEL MANAGEMENT ...................................................
54
G-1.4.
PROTECTION OF INDIVIDUALS, SOCIETY AND THE ENVIRONMENT ..........................
54
G-1.5.
BIOLOGICAL, CHEMICAL AND OTHER HAZARDS .............................................................
55
G-1.6.
PROTECTION OF FUTURE GENERATIONS ............................................................................
56
G-1.7.
NO UNDUE BURDENS ON FUTURE GENERATIONS ..........................................................
56
G-2
EXISTING FACILITIES ......................................................................................................................................
57
G-2.1.
LEGISLATIVE FRAMEWORK: ......................................................................................................
57
G-2.2.
KOEBERG: MAIN RESULTS OF SAFETY ASSESSMENTS PERFORMED ...........................
57
G-2.3.
NECSA: INCREASE IN STORAGE CAPACITY OF PIPESTORE ............................................
59
G-3
SITING OF PROPOSED FACILITIES..............................................................................................................
59
G-3.1.
SITE-RELATED FACTORS LIKELY TO AFFECT THE SAFETY ................................................
59
G-3.2.
SAFETY IMPACT OF THE FACILITY ............................................................................................
60
G-3.3.
PUBLIC ACCESS TO SAFETY RELATED INFORMATION ..........................................................
61
G-3.4.
CONSULTATION WITH CONTRACTING PARTIES ......................................................................
61
G-3.5.
NO UNACCEPTABLE EFFECTS ON OTHER CONTRACTING PARTIES .................................
62
G-4
DESIGN AND CONSTRUCTION OF FACILITIES ..........................................................................................
62
G-4.1.
LEGISLATION AND LICENSING PROCESS DURING DESIGN AND CONSTRUCTION ....
62
G-4.2.
DECOMMISSIONING AT THE DESIGN STAGE ............................................................................
63
G-4.3.
EXPERIENCE, TESTING AND ANALYSIS ........................................................................................
63
G-5
G-5.1.
PRIOR SAFETY ASSESSMENT AND ENVIRONMENTAL ASSESSMENT ...................................
66
G-5.2.
OPERATION SAFETY ASSESSMENTS AND ENVIRONMENTAL ASSESSMENTS ..................
66
G-6
OPERATION OF FACILITIES ...................................................................................................................................
67
G-6.1.
SAFETY ASSESSMENTS AND SAFETY CASES ...............................................................................
67
G-6.2.
OPERATIONAL LIMITS AND CONDITIONS .....................................................................................
68
G-6.3.
OPERATIONAL PROCEDURES ............................................................................................................
68
G-6.4.
ENGINEERING AND TECHNICAL SUPPORT ...................................................................................
69
G-6.5.
INCIDENT REPORTING .........................................................................................................................
69
G-6.6.
OPERATING EXPERIENCE FEEDBACK SYSTEM .............................................................................
69
G-6.7.
DECOMMISSIONING PLANS ...............................................................................................................
70
G-7
DISPOSAL OF SPENT FUEL ....................................................................................................................................
70
CRITICALITY AND RESIDUAL HEAT REMOVAL ....................................................................
ASSESSMENT OF SAFETY OF FACILITIES .........................................................................................................
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
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66
v
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SECTION H:
SAFETY OF RADIOACTIVE WASTE MANAGEMENT ......................................................................................
71
H-1
GENERAL SAFETY REQUIREMENTS ...................................................................................................................
71
H-1.1.
CRITICALITY AND RESIDUAL HEAT REMOVAL .............................................................................
71
H-1.2.
MINIMISATION OF RADIOACTIVE WASTE ......................................................................................
73
H-1.3.
INTERDEPENDENCIES IN RADIOACTIVE WASTE MANAGEMENT ...........................................
73
H-1.4.
PROTECTION OF INDIVIDUALS, SOCIETY AND THE ENVIRONMENT ....................................
74
H-1.5.
BIOLOGICAL, CHEMICAL AND OTHER HAZARDS.........................................................................
74
H-1.6.
PROTECTION OF FUTURE GENERATIONS .......................................................................................
75
H-1.7.
NO UNDUE BURDEN ON FUTURE GENERATIONS ........................................................................
75
H-2
EXISTING FACILITIES AND PAST PRACTICES ...................................................................................................
76
H-2.1.
SAFETY OF EXISTING RADIOACTIVE WASTE MANAGEMENT FACILITIES .............................
76
H-2.2.
REVIEWING THE RESULTS OF PAST PRACTICES ............................................................................
77
H-3
SITING OF PROPOSED FACILITIES .......................................................................................................................
78
H-3.1.
SITE-RELATED SAFETY FACTORS .......................................................................................................
78
H-3.2.
SAFETY IMPACT AFTER CLOSURE .....................................................................................................
79
H-3.3.
PUBLIC ACCESS TO INFORMATION ...................................................................................................
79
H-3.4.
CONSULTATION WITH CONTRACTING PARTIES ............................................................................
80
H-3.5.
NO UNACCEPTABLE EFFECTS ON OTHER CONTRACTING PARTIES .......................................
80
H-4
DESIGN AND CONSTRUCTION OF FACILITIES ................................................................................................
81
H-4.1.
CONTROL MEASURES FOR DESIGN AND CONSTRUCTION ......................................................
81
H-4.2.
CONCEPTUAL PLANS FOR DECOMMISSIONING AT THE DESIGN STAGE .............................
82
H-4.3.
TECHNICAL PROVISIONS FOR CLOSURE AT THE DESIGN STAGE ............................................
82
H-4.4.
EXPERIENCE, ANALYSIS AND TESTING ............................................................................................
82
H-5
ASSESSMENT OF SAFETY OF FACILITIES .........................................................................................................
83
H-5.1.
SAFETY AND ENVIRONMENTAL ASSESSMENT BEFORE CONSTRUCTION ..........................
83
H-5.2.
POST-CLOSURE SAFETY ASSESSMENT OF A DISPOSAL FACILITY ........................................
84
H-6
OPERATION OF FACILITIES ..................................................................................................................................
85
H-6.1.
ASSESSMENTS AND COMMISSIONING PROGRAMME ..............................................................
85
H-6.2.
OPERATIONAL LIMITS AND CONDITIONS .....................................................................................
86
H-6.3. THE USE OF ESTABLISHED PROCEDURES ......................................................................................................
87
H-6.4. ENGINEERING AND TECHNICAL SUPPORT ....................................................................................................
87
H-6.5. CHARACTERISATION AND SEGREGATION OF RADIOACTIVE WASTE ....................................................
87
H-6.6. REPORTING OF INCIDENTS ..................................................................................................................................
88
H-6.7. ANALYSIS OF OPERATING EXPERIENCES ........................................................................................................
89
H-6.8. DECOMMISSIONING PLANS ................................................................................................................................
89
H-6.9. CLOSURE PLANS .....................................................................................................................................................
89
H-7
INSTITUTIONAL MEASURES AFTER CLOSURE ...............................................................................................
90
H-7.1. PRESERVATION OF RECORDS .............................................................................................................................
90
H-7.2. INSTITUTIONAL CONTROLS ................................................................................................................................
90
H-7.3. INTERVENTION MEASURES DURING INSTITUTIONAL CONTROL ...........................................................
91
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
SECTION I:
TRANSBOUNDARY MOVEMENT ........................................................................................................................
92
SECTION J:
DISUSED SEALED SOURCES ...............................................................................................................................
94
J-1
FRAMEWORK FOR MANAGEMENT OF DISUSED SEALED SOURCES ....................................................
94
J-1.1.
AUTHORISATION OF WORK WITH SEALED SOURCES ..............................................................
94
J-1.2.
APPLICATION OF CONTROL .............................................................................................................
94
J-2
RE-ENTRY OF DISUSED SEALED SOURCES ...................................................................................................
95
SECTION K:
PLANNED ACTIVITIES TO IMPROVE SAFETY ................................................................................................
96
K-1
NATIONAL MEASURES .........................................................................................................................................
96
K-1.1.
NUCLEAR ENERGY POLICY ...............................................................................................................
96
K-1.2.
NATIONAL RADIOACTIVE WASTE DISPOSAL INSTITUTE ACT ...............................................
96
K-1.2.1.
PROVISIONS OF THE ACT ..................................................................................................................
96
K-1.3.
NATIONAL REGULATORY SELF-ASSESSMENT – IAEA PROJECT ...........................................
100
K-2
REGULATORS FORUMS........................................................................................................................................
101
K-3
INTERNATIONAL NUCLEAR REGULATORY CONFERENCE ......................................................................
101
K-4
QUALITY MANAGEMENT SYSTEM .................................................................................................................
102
K-5
REASSESSMENT FOLLOWING EVENTS AT FUKUSHIMA DAIICHI PLANT ...........................................
103
ANNEXES.................................................................................................................................................................
104
SECTION L:
ANNEX 1:
USED FUEL MANAGEMENT FACILITIES ........................................................................................
105
A1-1
USED FUEL MANAGEMENT FACILITIES AT KOEBERG NUCLEAR POWER PLANT: ............................
105
A1-1.1.
INTERIM WET MANAGEMENT FACILITY AT KNPP ....................................................................
105
A1-1.2.
INTERIM DRY FUEL MANAGEMENT FACILITY AT KNPP ........................................................
105
A1-2
USED FUEL MANAGEMENT FACILITIES AT NECSA: ..................................................................................
106
A1-2.1.
THE REACTOR POOL .........................................................................................................................
106
A1-2.2.
THABANA PIPESTORE ........................................................................................................................
107
ANNEX 2: INVENTORIES OF USED FUEL...........................................................................................................
108
A2-1
INVENTORY OF USED FUEL AT KOEBERG NUCLEAR POWER PLANT: .................................................
108
A2-2
INVENTORY OF USED FUEL AT NECSA, PELINDABA: ...............................................................................
108
ANNEX 3:
A3-1
A3-1.1.
PELSTORE ............................................................................................................................................
111
A3-1.2.
THABANA STORES 1-5 ....................................................................................................................
112
A3-1.3.
PELINDABA EAST BUS SHED ........................................................................................................
114
A3-1.4.
BUILDING A-WEST DRUM STORE ....................................................................................................
115
A3-1.5.
AREA 21 STORAGE FACILITY .............................................................................................................
115
A3-2
VAALPUTS NATIONAL RADIOACTIVE WASTE DISPOSAL FACILITY .......................................................
116
RADIOACTIVE WASTE MANAGEMENT FACILITIES ..................................................................
109
SOUTH AFICAN NUCLEAR ENERGY CORPORATION (NECSA) PELINDABA SITE ............................
109
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
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ANNEX 4:
INVENTORIES OF KOEBERG RADIOACTIVE WASTE ..................................................................
119
ANNEX 5:
INVENTORIES OF RADIOACTIVE WASTE AT NECSA FACILITIES ............................................
121
ANNEX 6:
TYPICAL INVENTORIES OF RADIOACTIVE WASTE AT NORM FACILITIES ..........................
123
ANNEX 7:
NECSA FACILITIES BEING DECOMMISSIONED ..........................................................................
134
ANNEX 8:
REFERENCE TO NATIONAL LAWS, REGULATIONS, REQUIREMENTS AND GUIDES.......
136
DEFINITIONS
.......................................................................................................................................................................................
140
ABBREVIATIONS ......................................................................................................................................................................................... 143
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
TABLE OF FIGURES
FIGURE 1: RADIOACTIVE WASTE MANAGEMENT POLICY AND STRATEGY FOR THE REPUBLIC OF SOUTH AFRICA... 5
FIGURE 2: KOEBERG USED FUEL POOL ................................................................................................................................................. 8
FIGURE 3: NNR ORGANISATIONAL STRUCTURE ............................................................................................................................... 26
FIGURE 4: KOEBERG NUCLEAR POWER PLANT .................................................................................................................................. 105
FIGURE 5: UFA CASKS IN STORAGE AT KNPP ........................................................................................................................................ 106
FIGURE 6: A SIDE VIEW OF THE CASTOR X/28F UFA CASKS ............................................................................................................. 106
FIGURE 7: SAFARI-1 FUEL RACK FROM THE TOP .................................................................................................................................. 106
FIGURE 8: A FRONTAL VIEW OF THE THABANA PIPESTORE ............................................................................................................. 107
FIGURE 9: VIEW OF THE PELINDABA SITE ............................................................................................................................................... 109
FIGURE 10: SECTION OF THE PELSTORE ON PELINDABA SITE ...................................................................................................... 112
FIGURE 11: SIDE VIEW OF THABANA STORE 1 .................................................................................................................................... 113
FIGURE 12: THABANA STORES 2 AND 3 ............................................................................................................................................... 114
FIGURE 13: AN AERIAL VIEW OF THE VAALPUTS SITE SHOWING DISPOSAL TRENCHES .................................................... 116
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
EXECUTIVE SUMMARY
The Republic of South Africa acceded to the Joint Convention on the Safety of Spent Fuel Management
and on the Safety of Radioactive Waste Management (Joint Convention) on 15 November 2006, and
South Africa’s obligations under the convention entered into force on 13 February 2007.
The Joint Convention establishes an international peer review process among Contracting Parties
and provides incentives for nations to take appropriate steps to bring their nuclear activities into
compliance with general safety standards and practices.
The first South African National Report was presented at the third Review Meeting of the
Contracting Parties under the Joint Convention in May 2009 in Vienna, Austria.
This second South African National Report updates the first report, which documented spent fuel
and radioactive waste management safety in the Republic of South Africa under the terms of the
Joint Convention. It also incorporates additional information and responses to questions raised at
the third review meeting of the Contracting Parties.
The Republic of South Africa is in compliance with the terms of the Joint Convention. A
comprehensive national legal and regulatory structure ensures the safety of used fuel and
radioactive waste management. The report describes used fuel and radioactive waste management
in the Republic of South Africa, providing annexes with information on used fuel and radioactive
waste management facilities, inventories, and ongoing decommissioning projects. Information
is provided on used fuel and radioactive waste management safety, as well as imports/exports
(transboundary movements) and disused sealed sources, as required by the Joint Convention.
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
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SECTION A: INTRODUCTION
A-1. BACKGROUND
Recognizing the importance of the safe management of spent nuclear fuel and radioactive
waste, the international community agreed upon the necessity of adopting a convention with
the objective of achieving and maintaining a high level of safety worldwide in spent fuel and
radioactive waste management: this was the origin of the Joint Convention on the Safety of Spent
Fuel Management and on the Safety of Radioactive Waste Management (the “Joint Convention”).
The Joint Convention was adopted on 5 September 1997 at a Diplomatic Conference
convened by the IAEA at its headquarters from 1-5 September 1997.
It was
opened for signature at the IAEA General Conference on 29 September 1997.
Pursuant to Article 40, the Joint Convention entered into force on 18 June 2001,
90 days after the date of deposit with the IAEA of the 25th instrument of ratification, acceptance
or approval, including the instruments of 15 States possessing operational nuclear power plants.
Since the entry into force of the Joint Convention, there have been three review meetings held at
the IAEA Headquarters in Vienna over the following periods:
(i)
First Review Meeting 3-14 November 2003;
(ii)
Second review Meeting 15-24 May 2006;
(iii)
Third Review Meeting
11-20 May 2009
The fourth review meeting is scheduled for the period 14-23 May 2012.
South Africa is a contracting party to the Joint Convention on the Safety of Spent Nuclear Fuel
Management and Safety of Radioactive Waste Management. South Africa acceded to the
convention on 15 November 2006 and its obligations under the convention entered into force on
13 February 2007. South Africa participated in the Third Review Meeting of the Joint Convention.
Provisions of the Joint Convention
The Joint Convention is the first international instrument that deals with the safety of management
and storage of spent fuel and radioactive waste in countries with and without nuclear programs.
It also considerably elaborates on and expands the existing IAEA nuclear safety regime and
promotes international standards in this area. The Joint Convention is aimed at achieving and
maintaining a high level of safety in spent fuel and radioactive waste management, ensuring that
there are effective defences against potential hazards during all stages of management of such
materials, and preventing accidents with radiological consequences.
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
The Joint Convention covers the safety of spent fuel and radioactive waste management from
civilian applications. It also applies to the management of military or defence-originated spent
fuel and radioactive waste if and when such materials are transferred permanently to and managed
within exclusively civilian programs.
The Joint Convention calls on the contracting parties to review safety requirements and conduct
environmental assessments both at existing and proposed spent fuel and radioactive waste
management facilities. It provides for the establishment and maintenance of a legislative and
regulatory framework to govern the safety of spent fuel and radioactive waste management.
The Joint Convention establishes rules and conditions for the transboundary movement of
spent fuel and radioactive waste that inter alia require a State of destination to have adequate
administrative and technical capacity and regulatory structure to manage spent fuel or radioactive
waste in a manner consistent with the Joint Convention. It obligates a State of origin to take
appropriate steps to permit re-entry into its territory of such material if a transboundary movement
cannot be completed in conformity with the Joint Convention.
A-2. PURPOSE
This report summarises South Africa’s approach to the safety of used fuel management and the
safety of radioactive waste management and demonstrates how South Africa fulfils its obligations
under the Joint Convention. This is South Africa’s second report on compliance to obligations
under the Joint Convention. The first report was produced in October 2008.
A-3. STRUCTURE OF THE REPORT
In developing the report South Africa has drawn from the experience acquired from the last review
meeting of the contracting parties of the Joint Convention and the five national reports under the
Convention on Nuclear Safety. The report constitutes a self-supporting report, based on existing
documentation, and reflects the viewpoints of the different regulatory authorities and operators.
This report is structured according to the “guidelines regarding national reports” for the Joint
Convention – i.e., an “article-by-article” format, with each one being addressed in a dedicated
chapter bearing the corresponding text of the relevant article of the Joint Convention on a shaded
background at the top of the chapter. After the Introduction (Section A), the various sections deal
successively with the following topics in the specific order prescribed by the guidelines:
• Section B: Policy and practices under the Joint Convention (Article 32-1);
• Section C: Scope (Article 3);
• Section D: Spent-fuel and radioactive-waste Inventories (Article 32-2);
• Section E: Legislative and regulatory system in force (Articles 18 to 20);
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
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• Section F: Other general safety provisions (Articles 21 to 26);
• Section G: The safety of spent-fuel management (Articles 4 to 10);
• Section H: The safety of radioactive-waste management (Articles 11 to 17);
• Section I: Transboundary movements (Article 27);
• Section J: Disused sealed sources (Article 28),
• Section K: Planned safety-improvement actions; and
• Section L: Annexes in support of Section D.
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
SECTION B: POLICIES AND PRACTICES
Article 32: Reporting
1. In accordance with the provisions of Article 30, each Contracting Party shall submit a national report to each review meeting of Contracting Parties. This report shall address the
measures taken to implement each of the obligations of the Convention. For each Contracting Party the report shall also address its:
(i)
spent fuel management policy;
(ii) spent fuel management practices;
(iii) radioactive waste management policy;
(iv) radioactive waste management practices;
(v) criteria used to define and categorize radioactive waste.
B-1. RADIOACTIVE WASTE MANAGEMENT POLICY FRAMEWORK OF SOUTH AFRICA
In May 2000, the Department of Minerals & Energy
initiated a process to develop a national policy for the
management of radioactive waste. Following a process
of national public consultation the Radioactive Waste
Management Policy and Strategy for the Republic of
South Africa, see Figure 1, was published in 2005.
Figure 1: Radioactive Waste Management Policy
and Strategy for The Republic of South Africa
The radioactive waste management policy and strategy
serves as the national commitment to address radioactive
waste management in a coordinated and cooperative
manner and represents a comprehensive radioactive
waste governance framework by formulating, additional
to nuclear and other applicable legislation, a policy
and implementation strategy in consultation with all
stakeholders.
The Policy and Strategy outlines the main policy principles that the Republic of South Africa will
endeavor to implement through its institutions in order to achieve the overall policy objectives
and is founded on the belief that all nuclear resources of the Republic of South Africa are a national
asset and the heritage of its entire people, and should be managed and developed for the benefit
of present and future generations in the country as a whole.
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The scope of the policy relates to all radioactive wastes and potential radioactive wastes (including
used fuel), except operational radioactive liquid and gaseous effluent discharges, which are
permitted to be released to the environment routinely under the authority of the relevant
regulators (National Nuclear Regulator (NNR) or the Directorate Radiation Control (RADCON)
under the Department of Health).
B-2. RADIOACTIVE WASTE MANAGEMENT PRACTICE
Within the South African regulatory framework, radioactive waste, for legal and regulatory purposes,
is defined as material that contains or is contaminated with radio-nuclides at concentrations or
activities greater than clearance levels as established by the regulatory body and for which no use
is foreseen.
It should be recognised that this definition is purely for regulatory purposes, and that material
with activity concentrations equal to or less than clearance levels is radioactive from a physical
viewpoint, although the associated radiological hazards are negligible.
In accordance with the Radioactive Waste Management Policy and Strategy for the Republic of
South Africa, final disposal is regarded as the ultimate step in the radioactive waste management
process, although a stepwise waste management process is acceptable. Long term storage of
certain types of waste e.g. high level waste, long lived waste and spent sources may be regarded
as one of the steps in the management process.
In practice the following hierarchy of waste management options shall be followed were
practicable:
• waste avoidance and minimisation;
• reuse, reprocessing and recycling;
• storage;
• conditioning and final disposal.
Radioactive material which could satisfy requirements for clearance, reuse, reprocessing or
recycling is considered as Potential Radioactive Waste, for example contaminated metal and used
nuclear fuel. The disposal and waste management options for the various classes of radioactive
waste are detailed in Table B-1.
As part of the South African strategy for long term radioactive waste management it is
envisaged that one site shall be developed for disposal of each of the waste classes
indicated in Table B.1, except in the case of NORM waste, which is disposed of in bulk,
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on the waste generator’s site. This is to maximise benefits from economies of scale of all
activities associated with disposal waste management.
At present the following disposal options are implemented in South Africa:
• above ground disposal in engineered facilities for the bulk of mining waste;
• near surface disposal for Low and Intermediate Level Waste at the Vaalputs National
Radioactive Waste Disposal Facility in the Northern Cape Province.
B-3. SPENT FUEL MANAGEMENT POLICY
In the South African context, the term “used fuel” is used instead of “spent fuel”. Pending the
outcome of current investigations into possible reprocessing of the used fuel to extract radioactive
isotopes for further use, used fuel is not classified as radioactive waste. Rather than being in its
final form for disposal used fuel is considered to still have useful material.
The Radioactive Waste Management Policy and Strategy for the Republic of South Africa prescribes
the domain within which used fuel shall be managed in South Africa. Used fuel is currently stored
in authorised facilities within the generator’s sites. Two mechanisms, i.e., dry and wet storage,
are currently in use in South Africa. The Policy and Strategy dictates that investigations shall be
conducted within set time frames to consider the various options for safe management of used
fuel and high level waste and states that the following options shall be investigated:
• long-term above ground storage in an off-site facility licensed for this purpose;
• reprocessing, conditioning and recycling;
• Deep geological disposal; and
• Transmutation.
It is required that the choice of the most suitable option must take due cognisance of policy
principles and objectives. All conclusions on investigations shall be subject to public scrutiny.
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B-4. SPENT FUEL MANAGEMENT PRACTICES
In South Africa, two mechanisms (Dry and Wet storage) are
currently in use for the management of used fuel.
Used fuel from the Koeberg Nuclear Power Station is
currently stored in authorised used fuel pools on the site
as well as in casks designed and constructed for storage of
used fuel. The Koeberg site has enough storage capacity
for the used fuel that will be generated during the current
operational lifetime of Koeberg Nuclear Power Station.
The used fuel from the SAFARI-1 Research Reactor is
initially stored in the reactor pool for at least two years to
facilitate cooling of the used fuel prior to it being
transferred to an authorised dry storage facility on the
Figure 2: Koeberg Used Fuel Pool
Pelindaba site.
It is recognised that the current storage capacity at the Koeberg and Pelindaba sites are finite and
the practice of storing used fuel on a reactor site is not sustainable indefinitely.
B-5. CRITERIA USED TO DEFINE AND CATEGORISE RADIOACTIVE WASTE
The National Radioactive Waste Classification Scheme (Table B-1) defines the criteria used to
define and categorise radioactive waste as well as the generic waste treatment/conditioning
requirements and possible disposal/management options.
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HLW
LILW-LL
1
2
Waste Class
Table B-1:
Radioactive waste with low or
intermediate short-lived radionuclide and intermediate longlived radionuclide concentrations.
4 Sealed sources
3 Fission and activation
products (nuclear power
generation and isotope
production)
2 Un-irradiated uranium
(nuclear fuel production).
1 Irradiated uranium (isotope
production).
Sealed sources
Used fuel declared as waste
or used fuel recycling
products
Waste type/Origin
Heat generating radioactive 1
waste with high long and shortlived radionuclide concentrations
2
Waste Description
Beta and gamma: <40000 Bq/g
v
3
Long-lived alpha, beta and gamma
emitting radionuclides at activity concentration levels that could result in inherent
intrusion dose (the intrusion dose assuming
the radioactive waste is spread on the surface) between 10 and 100 mSv per annum
(Maximum per waste package up to 10x the
concentration levels specified above). OR
Alpha: < 4000 Bq/g
v
Long-lived alpha radio nuclides (T ½
> 31 y) concentrations.
2.
Long-lived alpha, beta and
gamma emitting radionuclides at
activity concentration levels that
could result in inherent intrusion dose (the intrusion dose
assuming the radioactive waste is
spread on the surface) above 100
mSv per annum
3
Thermal power (mainly due to
shortlived radio nuclides (T ½
< 31 y) <2 kW/m3 ) AND
Long-lived alpha, beta and
gamma emitting radionuclides
at activity concentration levels >
levels specified for LILW-LL OR
2
1.
Thermal power > 2 kW/m3 OR
1
Waste Criteria
National Radioactive Waste Classification Scheme
Disposal/Management Options
Managed as NORM-E-Waste (unirradiated uranium)
Regulated medium depth disposal (10’s of meters)
(C) Long Term above ground storage
(b) Reprocessing, Conditioning and Recycling
(a) Regulated Deep Disposal (100’s of
meters)
1.
Waste package suitable for 1.
handling, transport and storage (storage period in order
of 50 years). The waste form
shall be solid with additional
characteristics as prescribed 2.
for a specific repository
Waste package suitable for
handling, transport and storage (storage period in order
of 100 years). The waste form
shall be solid with additional
characteristics as prescribed
for a specific repository
Generic waste treatment/
Conditioning requirements(*)
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VLLW
LILW-SL
(low activity)
5 NORM-L
4
3
Waste Class
Long-lived alpha radio nuclides(T ½
> 31 y) concentrations.
2.
3
Mining and minerals
processing.
Potential Radioactive waste 1
containing low concentrations
of NORM.
2
Bulk waste – unirradiated uranium (Nuclear fuel
production).
Fossil fuel electricity generation.
Contaminated or slightly
radioactive material originating from operation and
decommissioning activities.
3 Sealed sources.
1.
1.
3.
Long-lived radio nuclide concentration: <100 Bq/g.
Concentration or authorised discharge or reuse criteria and levels
approved by the relevant regulator.
Long-lived alpha, beta and gamma
emitting radionuclides at activity
concentration levels that could result
in inherent intrusion dose (the intrusion dose assuming the radioactive
waste is spread on the surface) below
10 mSv per annum
(Maximum per waste package up to 10x the
concentration levels specified above). OR
v Beta and gamma: <4000 Bq/g
v Alpha: < 400 Bq/g
Thermal power (mainly due to shortlived radio nuclides (T ½ < 31 y) <2
kW/m3 ) AND
1.
1 Un-irradiated uranium
(nuclear fuel production).
2 Fission and activation
products (nuclear power
generation and isotope
production).
Waste Criteria
Waste type/Origin
Radioactive waste containing 1
very low concentration of radioactivity.
Radioactive waste with low or
intermediate short-lived radionuclide and/or low long-lived
radionuclide concentrations.
Waste Description
Unpackaged waste in a miscible form
Extraction of any economically
recoverable minerals followed by
disposal in any mine tailings dam or
other sufficiently confined surface
impoundment
Authorised disposal
Clearance
3.
4.
Reuse as underground backfill material in an underground area
Authorized disposal discharge or
reuse
Clearance
Managed as NORM-E-Waste (unirradiated uranium)
Regulated near surface disposal
Disposal/Management Options
2.
1.
2.
Waste stream specific require- 1.
ments and conditions
Waste package suitable for 1.
handling, transport and storage (storage period in order
of 10 years). The waste form
shall be solid with additional 2.
characteristics as prescribed
for a specific repository
Generic waste treatment/
Conditioning requirements(*)
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Waste Description
1.
Long-lived radio nuclide concentration > 100 Bq/g.
Waste Criteria
(*)
Treatment and conditioning requirements are mainly dependent on specific waste type in a waste class
Soils contaminated with
scales
Scales
Waste type/Origin
6 NORM-E (en- Radioactive waste containing 1
hanced activity)
enhanced concentrations of
NORM.
2
Waste Class
Reuse as underground backfill material in an identified underground
area
Extraction of any economically
recoverable minerals followed by
disposal in any mine tailings dam or
other sufficiently confined surface
impoundment
Regulated deep or medium depth
disposal
2.
3.
Disposal/Management Options
Packaged or Unpackaged 1.
waste in a miscible or solid
form with additional characteristics for a specific repository
Generic waste treatment/
Conditioning requirements(*)
SECTION C: SCOPE OF APPLICATION
Article 3. Scope of Application
1. This Convention shall apply to the safety of spent fuel management when the spent fuel
results from the operation of civilian nuclear reactors. Spent fuel held at reprocessing facilities as part of a reprocessing activity is not covered in the scope of this Convention unless
the Contracting Party declares reprocessing to be part of spent fuel management.
2. This Convention shall also apply to the safety of radioactive waste management when the
radioactive waste results from civilian applications. However, this Convention shall not apply to waste that contains only naturally occurring radioactive materials and that does not
originate from the nuclear fuel cycle, unless it constitutes a disused sealed source or it is
declared as radioactive waste for the purposes of this Convention by the Contracting Party.
3. This Convention shall not apply to the safety of management of spent fuel or radioactive
waste within military or defence programmes, unless declared as spent fuel or radioactive
waste for the purposes of this Convention by the Contracting Party. However, this Convention shall apply to the safety of management of spent fuel and radioactive waste from
military or defence programmes if and when such materials are transferred permanently to
and managed within exclusively civilian programmes.
4. This Convention shall also apply to discharges as provided for in Articles 4, 7, 11, 14, 24 and
26.
C-1. USED FUEL AND REPROCESSING
The reprocessing, conditioning and recycling of used fuel are options currently being investigated
as part of the South African long-term management strategy for used fuel. These activities are not
presently being undertaken in South Africa.
Further, whilst South Africa is not currently investigating options for possible transmutation of
used fuel, South Africa continues to monitor international developments in this regard.
The used fuel arising from both the Koeberg Nuclear Power Station and the
SAFARI-1 Research Reactor falls under the scope of application of this National Report.
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C-2. THE SAFETY OF RADIOACTIVE WASTE MANAGEMENT
The scope of the South African policy and strategy on radioactive waste management relates to all
radioactive wastes, except operational radioactive liquid and gaseous effluent discharges, which
are permitted to be released to the environment routinely under the authority of the relevant
regulators (NNR or RADCON).
The safety of radioactive waste management is considered during all commissioning, operational
and decommissioning phases of regulated nuclear actions in South Africa. This includes:
• the operation of nuclear reactors and other facilities within the nuclear fuel cycle;
• the production and use of radioactive materials in the fields of research, medicine, industry,
agriculture, commerce, and education;
• the extraction, processing and combustion of raw materials containing naturally occurring
radioactive materials (NORM);
• environmental restoration programmes associated with any of the above.
As such, South Africa’s reporting under the Joint Convention relates to all radioactive wastes,
including radioactive waste that contains only naturally occurring radioactive material (NORM),
irrespective of whether such wastes arise from within the fuel cycle or not.
C-3. MILITARY OR DEFENCE PROGRAMMES
The Republic of South Africa has no active military or defence nuclear programmes. The Republic
of South Africa voluntarily discarded its former nuclear weapons programme and acceded to the
Treaty on the Non-Proliferation of Nuclear Weapons on 10 July 1991. The objectives of the treaty
are to prevent the spread of nuclear weapons, facilitate peaceful nuclear cooperation between
treaty members and provide a foundation for nuclear disarmament.
Further, the Pelindaba Treaty (also called the African Nuclear Weapons Free Zone Treaty) prohibits
the production of nuclear weapons in the African region. The Pelindaba Treaty was opened for
signature on 11 April 1996 and all 53 African Union members (including the Republic of South
Africa) have signed the treaty.
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C-4. DISCHARGES
Radioactive liquid and gaseous effluent discharges, which are permitted to be released to the
environment routinely under the authority of the relevant regulators (NNR or RADCON), are
reported on under the Joint Convention.
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SECTION D:
LISTS OF FACILITIES AND INVENTORIES
Article 32. Reporting, paragraph 2
1. This report shall also include:
(i) a list of the spent fuel management facilities subject to this Convention, their location, main purpose and essential features;
(ii) an inventory of spent fuel that is subject to this Convention and that is being held
in storage and of that which has been disposed of. This inventory shall contain a
description of the material and, if available, give information on its mass and its total
activity;
(iii) a list of the radioactive waste management facilities subject to this Convention, their
location, main purpose and essential features;
(iv) an inventory of radioactive waste that is subject to this Convention that:
(a)is being held in storage at radioactive waste management and nuclear fuel
cycle facilities;
(b)has been disposed of; or
(c)has resulted from past practices.
This inventory shall contain a description of the material and other appropriate
information available, such as volume or mass, activity and specific radionuclides;
(v)
a list of nuclear facilities in the process of being decommissioned and the status
of decommissioning activities at those facilities.
D-1 LIST OF THE USED FUEL MANAGEMENT FACILITIES
A list of used fuel management facilities, their location, main purpose, and essential features
are listed in Section L: Annex 1.
D-2 USED FUEL INVENTORIES
The inventory of used fuel from the Koeberg Nuclear Power Station and SAFARI-1 Research
Reactor is currently stored on the Koeberg and Pelindaba sites respectively and is detailed
in Section L: Annex 2.
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D-3 LIST OF THE RADIOACTIVE WASTE MANAGEMENT FACILITIES
A list of Necsa radioactive waste management facilities (disposal and
storage), their location, main purpose, and essential features are indicated in
Section L: Annex 3.
D-4 INVENTORY OF RADIOACTIVE WASTE
The inventories of radioactive
and low-level waste currently on
Section L: Annex 4.
waste arising from Koeberg intermediatesite up to 31 March 2011 is indicated in
The volume of radioactive waste in Necsa storage and disposal facilities is indicated in Section
L: Annex 5.
Radioactive Waste arising from typical actions involving NORM material is indicated in Section L:
Annex 6.
D-5 LIST OF NUCLEAR FACILITIES IN THE PROCESS OF BEING DECOMMISSIONED
A list of Necsa nuclear facilities in the process of being decommissioned and the status of
decommissioning activities are detailed in Section L: Annex 7.
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SECTION E: E-1
LEGISLATIVE AND REGULATORY SYSTEMS
IMPLEMENTING MEASURES
Article 18: Implementing Measures
Each Contracting Party shall take, within the framework of its national law, the legislative,
regulatory and administrative measures and other steps necessary for implementing its
obligations under this Convention.
In conformance to Article 18 of the Joint Convention, the Republic of South Africa has undertaken
the necessary legislative, regulatory and administrative measures to fulfil its obligations under the
Joint Convention and these are reported on in this report.
E-2
LEGISLATIVE AND REGULATORY FRAMEWORK
Article 19: Legislative and Regulatory Framework
1. Each Contracting Party shall establish and maintain a legislative and regulatory
framework to govern the safety of spent fuel and radioactive waste management.
2. This legislative and regulatory framework shall provide for:
3. (i)
the establishment of applicable national safety requirements and regulations
for radiation safety;
(ii)
a system of licensing of spent fuel and radioactive waste management
activities;
(iii)
a system of prohibition of the operation of a spent fuel or radioactive waste
management facility without a licence;
(iv)
a system of appropriate institutional control, regulatory inspection and
documentation and reporting;
(v)
the enforcement of applicable regulations and of the terms of the licences;
(vi)
a clear allocation of responsibilities of the bodies involved in the different
steps of spent fuel and of radioactive waste management.
When considering whether to regulate radioactive materials as radioactive waste,
Contracting Parties shall take due account of the objectives of this Convention.
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E-2.1.
LEGISLATIVE FRAMEWORK
The South African legislative framework on nuclear energy dates back to 1948 when the
predecessor of the present South African Nuclear Energy Corporation (Necsa), namely the Atomic
Energy Board (AEB), was created in terms of the provisions of the Atomic Energy Act. This Act was
amended over the years to keep pace with developments in nuclear energy. The establishment
of the Nuclear Installations Act, which came into force in 1963, made provision for the licensing of
Nuclear Installations by the Atomic Energy Board.
The Uranium Enrichment Corporation (UCOR) was created in 1970 in terms of the provisions of
the Uranium Enrichment Act, Act 33 of 1970. This allowed the enrichment of uranium by a State
Corporation separate from the AEB and subject to licensing by the latter.
A major change took place in 1982 when the Atomic Energy Corporation (AEC) was created and
made responsible for all nuclear matters, including uranium enrichment. This change was mandated
by the provisions of the Nuclear Energy Act, Act 92 of 1982. In 1988, a major amendment to the
Nuclear Energy Act (Nuclear Energy Amendment Act, Act 56 of 1988) created the autonomous
Council for Nuclear Safety (CNS), responsible for nuclear licensing and separate from the AEC.
The old Nuclear Energy Act was replaced by a new Act in 1993 (Nuclear Energy Act,
Act 131 of 1993). This maintained the autonomous character of the CNS but made provision for
the implementation of the Safeguards Agreement with the IAEA pursuant to the requirements of
the Nuclear Non-Proliferation Treaty to which South Africa acceded in June 1991.
At present the nuclear sector in South Africa is mainly governed by the Nuclear Energy Act, Act 46
of 1999 (NEA) and the National Nuclear Regulator Act, Act 47 of 1999 (NNRA), which superseded
the previous Nuclear Energy Act (Act 131 of 1993). Additionally the Hazardous Substances Act,
Act 15 of 1973 (HSA), provides for control of Group III hazardous substances (involving exposure
to ionising radiation emitted from equipment) and Group IV hazardous substances (radioactive
material not at nuclear installations or part of the nuclear fuel cycle, for example fabricated
radioactive sources and medical isotopes).
The governance and regulation of radioactive waste management is also subject to the provisions
of the following other acts:
• National Radioactive Waste Disposal Institute Act, Act No. 53 of 2008. (NRWDIA)
• Environment Conservation Amendment Act, Act 50 of 2003. (ECAA)
• Minerals and Petroleum Resources Development Act, Act No. 28 of 2002. (MPRDA)
• National Environmental Management Act, Act No. 107 of 1998. (NEMA)
• National Water Act, Act No. 36 of 1998. (NWA)
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• Water Services Act, Act No. 108 of 1997. (WSA)
• Mine Health and Safety Act, Act No. 29 of 1996. (MHSA)
• Environment Conservation Act, Act 73 of 1989. (ECA)
• Dumping at Sea Control Act, Act No. 73 of 1980. (DSCA)
In terms of section 46 of the Nuclear Energy Act, Act 46 of 1999, discarding of radioactive waste
and storage of irradiated nuclear fuel require the written permission of the Minister of Energy and
are subject to any conditions that the Minister, in concurrence with the Minister of Environmental
Affairs and the Minister of Water Affairs, deems fit to impose. The conditions so imposed will
be additional to any conditions contained in a nuclear authorisation as defined in the National
Nuclear Regulator Act, Act 47 of 1999.
E-2.2.
REGULATORY FRAMEWORK
E-2.2.1.
SAFETY REQUIREMENTS AND REGULATIONS FOR RADIATION
SAFETY;
The National Nuclear Regulator Act, Act 47 of 1999 (NNRA), provides the South African National
Nuclear Regulator (NNR) with a mandate to establish and enforce national standards in the areas
of radiological health and safety and environmental protection.
In terms of the NNRA, the NNR formulated national safety standards and regulatory practices which
were recommended by the NNR Board to the Minister of Minerals and Energy. The Safety Standards
and Regulatory Practices (SSRP), Regulation R 388 of 2006, were published on 28 April 2006 and
these regulations are being enforced on all holders of nuclear authorisations in the country. These
regulations are based on international safety standards and regulatory practices and provide for
criteria and requirements related to exclusion, exemption and regulation (authorisation by way of
Certificate of Registration or Licensing) of actions involving radioactive material.
Other regulations which were published, in terms of the NNRA, include the following:
• The regulations on the keeping of a record of all persons in a nuclear accident defined area,
Regulation R 778 of 2006.
• The regulations on the content of the annual report on the health and safety related to
workers, the public and the environment, Regulation R 716 of 2006.
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• The regulations on Establishment of Public Safety Information Forums, Regulation 968 of
2008.
• The regulations on Co-operative Governance in respect of the monitoring and control of
radioactive material or exposure to ionising radiation, Regulation 709 of 2002.
• The regulations on the prescribed format for the application for a nuclear installation
licence or a certificate of registration or a certificate of exemption, Regulation 1219 of 2007.
The Hazardous Substances Act, Act 15 of 1993 as amended, makes provision for the Minister of
Health to establish regulations:
• Authorising, regulating, controlling, restricting or prohibiting the manufacture,
modification, importation, storage, transportation or dumping and disposal of any
grouped hazardous substance or class of grouped hazardous substance.
• Providing for the appointment of such committees as may be considered necessary for the
purpose of advising the Director General on any matter concerning any Group III or Group
IV hazardous substance, the calling of meetings of any such committee, the quorum for
and procedure of such meeting.
• Regarding safety standards in connection with the importation into and exportation
from the Republic, manufacture, packing, disposal, dumping, sale, serving, applying,
administering or use of grouped hazardous substances and the manner in which such
standards shall be brought to the notice of persons concerned in any of said activities in
respect thereof, and in general with regard to any matter which the Minister considers
necessary or expedient to prescribe or regulate in order to attain or further the objects of
the Act.
In terms of the above provisions the Minister of Health has published regulations relating to Group
IV hazardous substances Regulation GN.R.247 dated 26 February 1993.
E-2.2.2.
LICENSING OF ACTIVITIES
The authorisation processes are defined in South African legislation (NNRA, NEA, HSA).
Prior to the granting of an authorisation the applicant is required to apply to the relevant
regulator (NNR or RADCON), in the prescribed format, detailing the intended activities and
providing a demonstration of the safety and compliance to the requirements and regulations.
The documentation submitted must address safety in the design of any facilities concerned
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and safety in the way the facility will be constructed, commissioned, operated, maintained and
decommissioned or closed.
In accordance with the provisions of section 21 of the NNRA “Any person wishing to site, construct, operate, decontaminate or decommission a nuclear
installation may apply in the prescribed format to the chief executive officer for a nuclear installation
licence and must furnish such information as the board requires”.
The above therefore represents the logical licensing stages that are applicable to any nuclear
installation. The applicant may however choose to combine individual stages; such combination
of stages may be approved by the regulator subject to the applicant ensuring that all the
necessary safety documentation relevant to the combined stages has been submitted.
The combinations of licensing stages need to be established with a view to streamlining and
scheduling of the licensing process. Allowance must be made for assessments that may prove
to be time-consuming. The applicant must produce a safety case for each licensing stage
or combination of licensing stages. Based on the applicant’s proposal for combination of
licensing stages, the NNR may impose hold a n d / or witness points. The applicant must not
proceed beyond an imposed hold or witness point without prior NNR approval.
A safety case is a collection of safety arguments and evidence in support of the safety of a
facility or action. The safety case provided must identify and characterise all sources of radiation
associated with the facility and all possible exposure pathways that may arise from such sources,
under normal operating conditions and under accident situations.
The NNR undertakes an evaluation of the submitted documentation to ensure that the
action or facility will meet the standards and requirements. From the evaluation, conditions are
identified for inclusion in the nuclear authorisation.
The authorisation conditions represent a framework within which the applicant or holder of
the nuclear authorisation is obliged to adhere to particular requirements in respect of design,
operation, maintenance and decommissioning and closure. The conditions of authorisation also
oblige the holder of the authorisation to provide a demonstration of compliance through the
submission of routine and non-routine reports.
Typical conditions included in a nuclear authorisation address:
• the description and configuration of the authorised facility or action;
• requirements in respect of modification to facilities;
• operational requirements in the form of operating technical specifications, procedures
or programmes as appropriate;
• maintenance testing and inspection requirements;
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• operational radiation protection programmes;
• radioactive waste management programmes;
• emergency planning and preparedness requirements as appropriate;
• physical security;
• transport of radioactive material;
• quality assurance; and
• reporting.
In accordance with the requirements of the NEMA, an environmental assessment has to
be conducted prior to the construction of a spent fuel management or radioactive waste
management facility. Further, the ECAA prescribes that no person may establish, provide or
operate a disposal site without a permit issued by the Minister of Environmental Affairs.
E-2.2.3.
PROHIBITION OF THE OPERATION WITHOUT AN AUTHORISATION
The legislative system prohibits the operation of a spent fuel or radioactive waste management
facility without appropriate authorisation.
The NNRA prohibits:
• siting, construction, operation, decontamination or decommission of a nuclear installation,
except under the authority of a nuclear installation licence;
• undertaking of any action not requiring a nuclear installation licence or a nuclear vessel
licence except under the authority of a certificate of registration or certificate of exemption.
The HSA provides that no person shall produce, otherwise acquire, or dispose of, or import into
the Republic or export from there, or be in possession of, or use or convey or cause to be conveyed,
any Group IV Hazardous substance, except in terms of a written authority issued by the Director
General of the Department of Health.
In accordance with the provisions of the N E A , the discarding of radioactive waste and storage
of irradiated nuclear fuel require the written permission of the Minister of Energy and are subject
to such conditions that the Minister in concurrence with the Minister of Environmental Affairs and
the Minister of Water Affairs, deems fit to impose. The conditions so imposed will be additional to
any conditions contained in a nuclear authorisation as defined in the NNRA.
Further, the ECAA prescribes that no person may establish, provide or operate a disposal site
without a permit issued by the Minister of Environmental Affairs.
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E-2.2.4.
REGULATORY INSPECTIONS, SAFETY DOCUMENTATION AND
REPORTING
The nuclear authorisation requires the holder to develop and maintain a documented safety case
which demonstrates compliance with the requirements of the applicable act and regulations and
which includes as a minimum:
• detailed description of the plant and site;
• scope of activities to be undertaken;
• specifications of systems, structures and components important to safety;
• onsite and off- site environmental factors or components relevant to nuclear and
radiation safety;
• plant operational safety assessment, including associated nuclear and radiation safety
rules, criteria, standards and requirements relevant to the safety assessment;
• operational safety related programmes and limiting conditions of operations including:
§programme for compliance with dose and risk limits as appropriate;
§programme to ensure that nuclear installations are built and operated according
to good engineering practice and international norms and standards;
§programme for incident and accident management including emergency
planning, preparedness and response;
§quality management programme;
§system of records and reporting;
§radiation protection programme;
§radioactive waste management programme;
§programme for transport of radioactive material;
§environmental monitoring and surveillance programme;
§programme for decommissioning.
The holder of a nuclear authorisation is responsible for ensuring that all operational safety related
programmes are procedurised and implemented accordingly. Further, the holder of a nuclear
authorisation is required in terms of the provisions of the NNRA to implement an inspection
programme to ensure compliance with the requirements of the nuclear authorisation and
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provide any information or monthly return as required by the NNR. This includes:
• reports on problem, incident and accident notification, investigation and closeout;
• quality assurance and audit reports including closeout reports;
• environmental monitoring reports;
• reports on liquid and gaseous effluent discharges.
The NNR conducts independent compliance assurance activities to determine the extent to
which holders of nuclear authorisations comply with the conditions of authorisation. The nature
of the NNR’s compliance assurance activities are commensurate with the nature of authorisation
issued and the risk posed by the facility or action. The compliance assurance activities involve
a combination of audits, routine inspections, non-routine inspections, review of routine reports
and review of occurrence reports.
E-2.2.5.
ENFORCEMENT
Offences and the appropriate sanction for the commission of such offences are contained in
the NNRA. The NNR may, in terms of the NNRA, revoke a nuclear installation licence at any time.
It is furthermore empowered to impose such conditions, as it deems necessary for preventing
nuclear damage, upon the holder of the relevant nuclear installation licence, during his period of
responsibility as defined.
E-2.2.6.
ALLOCATION OF RESPONSIBILITIES
The Radioactive waste Management Policy and Strategy for the Republic of South Africa,
clearly defines the responsibilities of Government, Regulatory Bodies as well a s generators of
radioactive waste and operators of radioactive waste disposal facilities. Further, the policy makes
provision for the establishment of a National Committee on Radioactive Waste Management, to
oversee the implementation of the national policy and strategy on radioactive waste management,
and a National Radioactive Waste Disposal Institute (NRWDI).
To give effect to Cooperative Governance as per the constitution of the Republic, the National
Nuclear Regulator and the following Government Departments are represented on the National
Committee on Radioactive Waste Management:
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• The Department of Environmental Affairs;
• The Department of Health (RADCON);
• The Department of Water Affairs.
In accordance with the provisions of section 6 of the NNR Act, the NNR is required to enter into cooperative governance agreements with other organs of State that have overlapping functions
or responsibilities. The purpose of the agreements is to:
• ensure the effective monitoring and control of nuclear hazards;
• co-ordinate and minimise the duplication and procedures for the exercise of such
functions; and
• promote consistency in the exercise of such functions.
E-3
THE ESTABLISHMENT OF A REGULATORY BODY
Article 20: Regulatory Body
1. Each Contracting Party shall establish or designate a regulatory body entrusted with
the implementation of the legislative and regulatory framework referred to in Article 19,
and provided with adequate authority, competence and financial and human resources
to fulfil its assigned responsibilities.
2. Each Contracting Party, in accordance with its legislative and regulatory framework,
shall take the appropriate steps to ensure the effective independence of the regulatory
functions from other functions where organizations are involved in both spent fuel or
radioactive waste management and in their regulation.
E-3.1.
NATIONAL NUCLEAR REGULATOR
The National Nuclear Regulator (NNR) is the national authority responsible for exercising regulatory
control over the safety of nuclear installations, radioactive waste, irradiated nuclear fuel, and the
mining and processing of radioactive ores and minerals. The primary function of the NNR is to
protect workers and members of the public from the harmful effects (i.e. nuclear damage) arising
from exposure to ionising radiation.
The NNR, established as an independent juristic person in terms of the provisions of the NNRA, is
comprised of a Board, a Chief Executive Officer and staff. The mandate and authority of the NNR
are conferred through sections 5 and 7 of the NNRA, which detail the objectives and functions
of the NNR.
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The powers of the NNR under the NNRA embrace all actions aimed at providing the public with
confidence and assurance that the risks arising from the undertaking of actions involving radioactive
material to which the NNRA applies, remain within acceptable safety limits. In practice this has
led to the NNR establishing safety standards and regulatory practices including probabilistic risk
limits and derived operational standards, conducting proactive safety assessments, determining
conditions of authorisation and obtaining assurance of compliance thereto.
The competence of the NNR is ensured through both its autonomous establishment and its
funding provisions which consist of monies appropriated from parliament, fees paid to the
regulator in respect of nuclear authorisations and donations or contributions received by the
regulator with the approval of the Minister of Energy.
E-3.2.
ORGANISATION OF THE NNR
The organisational structure of the NNR is depicted in Figure 3 below
Figure 3: NNR Organisational Structure
(i)
THE BOARD OF DIRECTORS:
The Executive of the regulatory body reports to a Board, which is appointed by the Minister of
Energy. The Board consists of twelve Directors including an official from the Department of
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Minerals and Energy, an official from the Department of Environmental Affairs, a representative of
organised labour, a representative of organised business, a representative of communities which
may be affected by nuclear activities and up to seven other Directors who hold office for a period
not exceeding three years, although they are eligible for re-appointment.
A person is disqualified from being appointed to or remaining a director of the Board if he or she,
inter alia, is:
• a holder of a nuclear authorisation or an employee of such holder;
• becomes a member of parliament, a provincial legislature, a municipal council, the Cabinet
or the executive council of a province.
(ii)
THE CHIEF EXECUTIVE OFFICER:
The Chief Executive Officer is appointed by the Minister of Energy and is also a member of the
Board. The Chief Executive Officer is the accounting officer of the Board and has the responsibility
to ensure that the functions of the Regulator are performed in accordance with the NNRA and
the Public Finance Management Act. The Chief Executive Officer holds office for a period not
exceeding three years as specified in the letter of appointment and may be reappointed upon
expiry of that term of office.
(iii)
THE STAFF OF THE REGULATOR:
The NNR’s organisational structure is configured to perform the following core functions:
(a)
Compliance Assurance and Enforcement (CAE)
The CAE group is responsible for conducting compliance inspections and enforcement on the
holders of nuclear authorisations currently comprising the following “Programmes”:
• Nuclear Power Plants (NPP)
• Nuclear Technology and Waste Products (NTWP)
• Naturally Occurring Radioactive Material (NORM)
(b)
Standards, Authorisation, Review and Assessment (SARA)
Management of Regulatory Programmes
Currently the NNR has three Regulatory Programme Managers (NPP, NTWP, NORM) who are
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responsible for the planning of assessment activities and liaison with the authorisation holders.
The Programme Manager: NPP is responsible for exercising regulatory control over Koeberg
Nuclear Power Station, including transport of radioactive material to and from Koeberg.
The Programme Manager: NTWP is responsible for exercising regulatory control over activities
undertaken by Necsa at the Pelindaba Site (covering research reactors, nuclear fuel fabrication
facilities, nuclear technology applications) and the disposal of low and intermediate level
waste at the Vaalputs site.
The Programme Manager: NORM is responsible for exercising regulatory control over naturally
occurring radioactive material arising primarily from the mining and mineral processing of
radioactive ores.
Review and Assessment
The Review and Assessment Group renders technical assessment functions to all the divisions
and consists of 4 functional subgroups:
• Design Safety
• Operational Safety
• Environmental and Radiation Protection
• Nuclear Security and Emergency Preparedness
The functional responsibilities of the Review and Assessment Group, include:
• Review of submissions from holders or applicants as requested by the Programme
Managers (NPP, NTWP, NORM)
• Conduct related safety assessments
• Assist in Enforcement/compliance assurance on request from CAE.
• Perform independent assessment of nuclear emergency preparedness at nuclear
installations
Special Nuclear Projects
The Special Projects Team coordinates the following activities:
• Regulatory Research
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• Development of Regulatory Guidance Documents,
• Development of Safety Standards,
• Development of Position Papers,
• Review of international standards, trends and best practices.
(c)
Support Services
The support services include Finance, Corporate Services, Strategic Planning, Communications
and Stakeholder Relations and Legal Counsel.
E-3.3.
INDEPENDENCE OF THE REGULATORY FUNCTION
The independent authority of the NNR is “de jure” entrenched in the NNRA, subject to the extent
that powers are conferred on the Minister of Energy to appoint the governing, non-executive
Board of Directors and the Chief Executive Officer.
The NNR operates independent from the government in terms of carrying out its mandate that
ensures that public health is assured for all South Africans that are exposed to nuclear and radiation
hazards. The purpose of this independence is established in order to ensure that regulatory
decisions are made free of other interest that may conflict with safety.
The NNRA makes provision for a comprehensive appeals process and specifically forbids any
representative of an authorisation holder or political structure from being appointed as a director
of the Board or the Chief Executive Officer.
With regards to the “de facto” independence of the NNR the NNRA provides that if the Minister
rejects a recommendation of the Board, on the contents of regulations to be published, the
Minister and Board must endeavour to resolve their disagreement. Although in the absence of
resolution of such disagreement, the Minster has the power to make the final decision. No
failure to resolve disagreement has thus far emerged regarding the relevant recommendations
from the Board.
The NNR is directly accountable to parliament, through the Minister of Energy, on nuclear and
radiation safety issues and operates independent from Government, to the extent that it is
able to carry out its mandate without undue influence being brought upon it
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SECTION F:
F-1
GENERAL SAFETY PROVISIONS
RESPONSIBILITY OF THE LICENCE HOLDER
Article 21: Responsibility of the licence holder
1. Each Contracting Party shall ensure that prime responsibility for the safety of spent fuel
or radioactive waste management rests with the holder of the relevant licence and shall
take the appropriate steps to ensure that each such licence holder meets its responsibility.
2. If there is no such licence holder or other responsible party, the responsibility rests with
the Contracting Party, which has jurisdiction over the spent fuel or over the radioactive
waste.
F-1.1.
RESPONSIBILITY FOR SAFETY
As a principle the South African Regulatory framework requires that the primary responsibility for
ensuring protection of the health and safety of the workers and members of the public as well
protection of the environment rests with the holder or applicant for a nuclear authorisation and
extends in an unbroken chain through the line managers to the workers in the facility.
As an external “action-forcing” agency, the Regulator influences the actions of the holder/
applicant only to the extent necessary to ensure adequate protection of the public and worker
health and safety. While the Regulator may identify current and potential safety problems and
offer alternative strategies for addressing each issue, resolving these safety problems remains
the sole responsibility of the holder/applicant. It is recognized that regulation can bolster but
never replace the commitment of line management and the workers to integrating proper
health and safety practices in work planning and performance.
The NNR ensures that the nuclear authorisation holder meets its primary responsibility with
regard to safety essentially by the establishment of safety standards, the issuance of a nuclear
authorisation and regulatory letters and by a compliance assurance programme, the latter
comprising inspections, surveillances and audits as well as various forums for interaction with the
nuclear authorisation holder.
These requirements include requirements for the nuclear authorisation holder to maintain effective
safety related processes independent of production. Safe practices are achieved by ensuring that
the nuclear authorisation holder complies with the conditions of the nuclear installation licence.
Holders of and applicants for nuclear authorisations demonstrate their compliance with regulatory
requirements, Health, Safety and Environmental (HSE) legislation, permits, licence conditions,
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national and international norms and standards through holder and applicant specific policy
and standards documents. The following aspects are generally covered in nuclear authorisation
holder or applicant specific documents:
• safety policy and philosophy;
• licensing strategies;
• integrated safety assessments;
• identification of radioactive waste categories;
• determination of radioactivity content;
• classification of radioactive waste;
• processing and conditioning of radioactive waste;
• storage and material accounting;
• identification of waste management end points;
• receipt, disposal and transport guidelines;
• administrative guidelines;
• exclusions;
• holder inspections programmes;
• non-compliance identification and reporting;
• radiation protection programme and radiation dose limitation;
• facility security;
• management of radioactive effluents including control of radioactive discharges to the
environment.
F-1.2.
RESPONSIBILITY IN ABSENCE OF NUCLEAR AUTHORISATION HOLDER
In accordance with the legislative requirements, the nuclear authorisation holder whose operations
generates or has generated used fuel or radioactive waste is responsible for all radioactive waste
management measures and the associated costs, in accordance with the “polluter pays” principle.
It is a pre-condition to the granting of a nuclear authorisation that the applicant demonstrate
the ability to safely manage all radioactive waste which may arise from the proposed operations.
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Regulatory oversight of authorised nuclear facilities and actions is accomplished in cooperation
with other national agencies and regulators, in compliance with the NNRA, and other applicable
laws. The NNR requires a smooth transition as nuclear facilities and actions pass from one life cycle
stage to the next (siting, construction, commissioning, operations, end of life, decontamination
and decommissioning including clean-up, demolition, and environmental restoration activities).
In terms of the Radioactive Waste Management Policy and Strategy for the Republic of South
Africa ownerless radioactive waste (radioactive waste where the generator no longer exists or
cannot be identified through reasonable means or does not have the resources to manage such
waste) is the responsibility of the Government. At present Necsa fulfils Government’s obligations
in this regard. In the future this responsibility will be vested with the soon to be established
National Radioactive Waste Disposal Institute (NRWDI).
F-2
HUMAN AND FINANCIAL RESOURCES
Article 22: Human and financial resources
Each Contracting Party shall take the appropriate steps to ensure that:
(i)
qualified staff are available as needed for safety-related activities during the operating lifetime of a spent fuel and a radioactive waste management facility;
(ii)
adequate financial resources are available to support the safety of facilities for spent
fuel and radioactive waste management during their operating lifetime and for decommissioning;
(iii)
financial provision is made which will enable the appropriate institutional controls
and monitoring arrangements to be continued for the period deemed necessary following the closure of a disposal facility.
F-2.1.
QUALIFIED STAFF
In accordance with the provisions of the SSRP:
“An adequate number of competent, qualified and trained staff must be responsible for carrying out the
functions associated with radiation protection and nuclear safety and for maintaining an appropriate
safety culture.”
Thus the nuclear authorisation holder has the primary responsibility for ensuring that the
employees are qualified and authorised to undertake their jobs. Nuclear authorisation holders
are required to report to the NNR on their staffing and competency level. Nuclear authorisation
holder employee training programmes include initial, complementary and refresher training
programmes
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The Nuclear Fuel Department of Eskom is responsible for human resource planning to fulfil
corporate responsibilities in accordance with Eskom requirements for resource management.
Managers at Necsa are responsible for human resource planning to fulfil corporate responsibilities
in accordance with Necsa’s requirements for resource management. This includes the
identification and provision of personnel training and orientation requirements as prescribed in
their management system. Necsa has also implemented a knowledge management program in
order to involve all employees in identifying and solving problems to ensure that the workforce is
suitably qualified and experienced.
All the mines have established a radiation protection function with sufficient staff responsible for
all activities with regard to radiation safety.
F-2.2.
FINANCIAL RESOURCES
In general, the financing for decommissioning and waste management follows the rule of
“polluter pays”. In accordance with this principle all nuclear authorisation holders are responsible
for ensuring that sufficient resources are in place to meet their responsibilities with respect to
decommissioning and radioactive waste management.
Further, it is a requirement of the SSRP, that it must be demonstrated to the regulator that
sufficient resources will be available from the time of cessation of the operation to the termination
of the period of responsibility.
Decommissioning and waste disposal is currently taking place in the following areas:
• low and intermediate level waste from Koeberg and Necsa Pelindaba site is disposed of in
shallow land- fill trenches at Vaalputs, the National Radioactive Waste Repository operated
by Necsa and situated about 600 km north of Cape Town. Although the State financed
the initial development costs of the site, Eskom a n d N e c s a pay fees based on
the amount of radioactive material sent to Vaalputs.
• decommissioning and associated waste management of Necsa’s two former enrichment
plants (the Y and Z plants) as well as the former conversion plant (U plant) and associated
facilities are undertaken by Necsa itself and the financing is carried by the State through
the annual State allocation for operational funds;
• decommissioning of disused mine equipment (primarily in the gold, copper, phosphate
and mineral sands operations) are currently undertaken. The mining companies finance
the decommissioning costs themselves and subcontract the operations out to specialized
agencies.
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• Decommissioning of the Koeberg nuclear power station is currently scheduled for after
2035. Financial provision for the decommissioning and used fuel management has
continued to be accumulated on a monthly basis since commercial operation of the
installation began in 1984.
The Radioactive Waste Management Policy and Strategy for the Republic of South Africa, makes
provision for a national Radioactive Waste Management Fund that will be managed by the South
African Government. Waste generators will contribute to the fund based on the radioactive waste
classes and volumes produced. The fund is aimed at ensuring sufficient provision for the long
term management of radioactive waste and includes the following:
• funding for disposal activities;
• funding for research and development activities including investigations into waste
management/disposal options;
• funding of capacity building initiatives for radioactive waste management; and
• funding for other activities related to radioactive waste management.
Management at Eskom and Necsa are responsible for determining the financial resources necessary
to achieve legal responsibilities through the budgeting programme, including adequate funding
for the management of used fuel and the disposal of intermediate and low-level waste. Similar
arrangements are in place for the mines.
F-2.3.
FINANCIAL
FACILITIES
PROVISION
FOR
POST-CLOSURE
MANAGEMENT
OF
An “After-care” fund has been established for the Vaalputs repository to finance activities in the
institutional control period.
Financial provision for closure and post closure of mining and mineral processing operations is
regulated by Directorate Mineral Resources in terms of the Minerals and Petroleum Resources
Development Act, Act No. 28 of 2002 (MPRDA) and is funded by the mines.
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F-3
QUALITY ASSURANCE
Article 23: Quality assurance
Each Contracting Party shall take the necessary steps to ensure that appropriate quality
assurance programmes concerning the safety of spent fuel and radioactive waste
management are established and implemented.
One of the principal nuclear safety requirements of the SSRP requires that a quality management
programme must be established, implemented and maintained in order to ensure compliance
with the conditions of the nuclear authorisation. The implementation of a quality management
programme is required to provide adequate confidence in the validity of the operational safety
assessment and safety assurance processes.
All holders of nuclear authorisations have a quality assurance program in place and the achievement
and maintenance of quality is verified by audits, surveillances, self-assessments and peer reviews.
Personnel undertaking monitoring activities are independent of direct responsibility for the
activity being monitored. The detection, correction of and taking of future preventative actions
related to non-conformances, deficiencies and deviations from quality requirements are specified
in various authorised procedures.
Management reviews are conducted on an annual basis. The inputs for management reviews are
obtained from monitoring activity reports, corrective action reports, quality deficiency reports
and other reporting mechanisms. During these reviews an assessment of the current quality
assurance programme is performed and the programme is amended as required.
The NNR audits the implementation thereof on a frequent basis.
F-3.1.
QUALITY ASSURANCE AT NECSA
The quality activities and behavioural performance are managed by means of a Quality
Management System. The quality department is responsible to ensure the quality management
system is established, implemented and maintained.
The roles and responsibilities with regards to implementation and management of the quality
processes are defined in the quality management systems manual. A quality policy is designed to
set the overall direction.
A quality management system is developed to provide management with a comprehensive
feedback on the overall performance of the plant. Regular audits and inspections are conducted
to determine the extent of compliance.
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The auditors assess compliance annually via internal audits. Audit reports are compiled and
submitted to management and assistance is provided to rectify non-conformances/deficiencies.
Activities affecting quality performance are performed in accordance with documented
instructions, procedures, drawings or appropriate qualitative acceptance criteria to ensure
satisfactory results are attained. Each process is described to a level of detail, commensurate with
its complexity and the need to ensure consistent and acceptable results.
Quality awareness training is conducted on a continuous basis to ensure sustainable operations
and to foster a culture of continual improvement.
Annual management reviews are conducted to ensure continuing suitability, adequacy and
effectiveness of the system. Measurable quality objectives are established at all levels within
the organization. Skills are identified via the balance scorecard and the individual development
programme is implemented to ensure the training needs are met.
The inspection measuring and test equipment are identified and calibrated at defined frequencies.
The core management procedures that describe the quality management system are as follows,
namely:
• control of documents;
• control of records;
• control of non-conformances;
• internal audits;
• corrective action;
• preventive action.
The work environment is controlled via the implementation of an environmental management
system and an occupational, health and safety management system. Various methods of
communication are applied, namely: internet, emails, notice boards, intranet, meetings, road
shows etc.
A waste management plan is in place to ensure effective control of solid and liquid waste.
Quarterly and annual reports are compiled for Top Management to ensure effective controls.
Personnel performing work affecting quality are adequately trained and authorized to perform
specified tasks.
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F-3.2.
QUALITY ASSURANCE AT ESKOM
Eskom’s Quality Assurance (QA) programme, including the Quality Policy Directive, is specified in
the Safety and Quality Management Manual of its Nuclear Division. Oversight of the operations is
provided by the QA programme of Koeberg Nuclear Power Station. This programme is based on
the IAEA Safety Code 50-C/SG-Q, the NNR Licence Document LD-1023 and Eskom Nuclear Division
Safety and Quality Management Manual.
The responsibility for the implementation of quality assurance policies on the operational plant
is that of the Koeberg Power Station Manager being accountable to the Senior General Manager
(Nuclear Division). The licence holder’s quality management and operational QA programmes
presently satisfy both the international standards and codes and those of the NNR.
A comprehensive audit programme of planned, periodic monitoring for the nuclear installation
has been established by the licence holder in conformance with NNR’s licensing requirements. This
programme is informed by indicators which include audit findings, inspection non-compliances,
operating experience and problem reports. The audit programme is discussed with the NNR and
takes into account the NNR’s planned audit and inspection programme to ensure an integrated
monitoring programme is established.
Achievement and maintenance of quality are verified by audits, surveillances, self-assessments and
peer reviews. These are conducted in accordance with authorised procedures and are performed
by certificated auditors using approved checklists. Personnel performing monitoring activities
are independent of direct responsibility for the activity being monitored.
Monitoring reports are issued and reviewed for comment by the monitored organisation. Follow
up action is taken to verify that deficiencies or discrepancies have been corrected. The results of
monitoring activities and management reviews are maintained as quality assurance records. The
detection, reporting, disposition and correction of non-conformances, deficiencies and deviations
from quality requirements are specified in various authorized procedures. Nonconforming items
are conspicuously marked and where possible segregated from other items.
Management reviews are conducted on an annual basis. The base material for management
reviews is obtained from monitoring activity reports, corrective action reports, quality deficiency
reports and other reporting mechanisms. During these reviews an assessment of the adequacy of
the current QA programme is performed and changes are made if deemed necessary.
Non-conformances for components are dispositioned as follows: use-as-is, repair, rework, or
unfit-for-purpose based on review and evaluation by responsible, competent engineers. Nonconformance dispositions are reviewed and accepted by responsible management.
Conditions adverse to quality include failures, malfunctions, deficiencies, deviations, defective
material or equipment, incorrect material or equipment. Significant conditions adverse to quality
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
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involve programmatic problems, as opposed to individual failures.
Conditions adverse to quality are identified and corrected. Significant conditions adverse to
quality are identified, the root cause of the condition determined, and corrective action taken to
prevent repetition. Appropriate management is informed.
Vendors are classified according to a 4-tier quality level system, based on the service/materials
they provide and the safety classification of the plant which requires the vendor intervention.
Quality levels 1&2 vendors (highest quality classification) are assessed by the nuclear installation
according to ISO 9001 and other pertinent criteria. Controls are in place to prevent inadvertent
use of incorrectly classified vendors.
Permanent QA records are retained for the life of the item to which they refer. Record storage
facilities have been constructed to prevent damage or deterioration of records due to fire, flooding,
insects, rodents and adverse environmental conditions.
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F-4
OPERATIONAL RADIATION PROTECTION
Article 24: Operational radiation protection
1. Each Contracting Party shall take the appropriate steps to ensure that during the operating
lifetime of a spent fuel or radioactive waste management facility:
(i)
the radiation exposure of the workers and the public caused by the facility shall
be kept as low as reasonably achievable, economic and social factors being taken into account;
(ii)
no individual shall be exposed, in normal situations, to radiation doses which
exceed national prescriptions for dose limitation which have due regard to internationally endorsed standards on radiation protection; and
(iii)
measures are taken to prevent unplanned and uncontrolled releases of radioactive materials into the environment.
2. Each Contracting Party shall take appropriate steps to ensure that discharges shall be limited:
(i)
to keep exposure to radiation as low as reasonably achievable, economic and social factors being taken into account; and
(ii)
so that no individual shall be exposed, in normal situations, to radiation doses
which exceed national prescriptions for dose limitation which have due regard to
internationally endorsed standards on radiation protection.
3. Each Contracting Party shall take appropriate steps to ensure that during the operating lifetime of a regulated nuclear facility, in the event that an unplanned or uncontrolled release
of radioactive materials into the environment occurs, appropriate corrective measures are
implemented to control the release and mitigate its effects.
F-4.1.
OPERATIONAL RADIATION PROTECTION: LEGAL FRAMEWORK
The NNRA makes provision for the NNR to impose any condition in a nuclear authorisation, which
is deemed necessary to ensure the protection of persons, property and the environment against
the risk of nuclear damage. The fundamental radiation protection criteria are detailed in the SSRP,
Regulation R.388. These include the prescribing of dose limits for workers and members of the
public as well as the setting of dose constraints for public exposure.
F-4.1.1.
DOSE LIMITS
In achieving the objectives for the control of occupational exposure, the NNR requires
that no individual shall receive an annual dose in excess of the prescribed dose limits and that all
exposures are as low as is reasonably achievable.
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The NNR has prescribed dose limits for both members of the public and the occupationally
exposed workforce. These limits are detailed as follows:
a) Occupational exposure
The occupational exposure of any worker shall be so controlled that the following limits are not
exceeded:
• an (average) effective dose of 20 mSv per year averaged over five consecutive years;
• a (maximum) effective dose of 50 mSv in any single year;
• an equivalent dose to the lens of the eye of 150 mSv in a year; and
• an equivalent dose to the extremities (hands and feet) or the skin of 500 mSv in a
year.
• in special circumstances, provided that radiation protection in the action has been
optimised but occupational exposures still remain above the dose limit the Regulator
may approve a temporary change in the dose limit subject to the agreement of the
affected employees, through their representatives where appropriate, and provided
that all reasonable efforts are being made to improve the working conditions to the
point where compliance with the dose limits can be achieved. This temporary change
shall not exceed 5 years and shall not be renewed.
b) Apprentices and students
For apprentices of 16 to 18 years of age who are training for employment involving exposure
to radiation and for students of age 16 to 18 who are required to use sources in the course of
their studies, the occupational exposure shall be so controlled that the following limits are not
exceeded:
• an effective dose of 6 mSv in a year;
• an equivalent dose to the lens of the eye of 50 mSv in a year; and
• an equivalent dose to the extremities or the skin of 150 mSv in a year.
c) Women
The annual effective dose limit for women of reproductive capacity is the same as that which is
generally specified for occupational exposure. Following declaration of pregnancy, a limit on the
equivalent dose to the abdomen of 2 mSv for the remainder of the pregnancy applies.
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d) Emergencies
In the event of an emergency or when responding to an accident, a worker who undertakes
emergency measures may be exposed to a dose in excess of the annual dose limit for persons
occupationally exposed:
• for the purpose of saving life or preventing serious injury;
• if undertaking actions intended to avert a large collective dose; or
• if undertaking actions to prevent the development of catastrophic conditions.
Under any of the above circumstances, all reasonable efforts must be made to keep doses to the
worker below twice the maximum annual dose limit. In respect of life-saving interventions,
every effort shall be made to keep doses below ten times the maximum annual dose limit. In
addition, workers undertaking interventions which may result in their doses approaching or
exceeding ten times the annual dose limit may only do so when the benefits to others clearly
outweigh their own risk.
e) Exposure of visitors and non-occupationally exposed workers at sites
The annual effective dose limit for visitors to the sites and those not deemed to be occupationally
exposed is 1 mSv. The annual dose equivalent limit for individual organs and tissues of such
persons is 10 mSv.
f) Public exposure
The annual effective dose limit for members of the public from all authorised actions is 1 mSv.
No action may be authorised which would give rise to any member of the public receiving a
radiation dose from all authorised actions exceeding 1 mSv in a year. To ensure compliance with
this limit a public dose constraint of 0.25 mSv per annum is applied at authorised sites.
Holders of nuclear authorisations are required to establish complementary operational
programmes, which are sufficiently comprehensive to ensure compliance with those limits. These
are augmented by operational verification programmes on aspects relating to radiation protection
in design in order to ensure that the parameters of the safety assessment remain current and to aid
in ensuring that the operational programmes are not compromised. The necessary principles are
embodied in the nuclear licence and in licence holder’s programme on Radiological Protection.
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F-4.1.2.
ALARA FOR WORKERS AND PUBLIC
The ALARA programmes at Eskom and Necsa are aimed at minimising radiation doses. A hazardgraded approach is used to determine safety requirements for radiation risks associated
with facilities during normal operations as well as during abnormal or accident conditions.
Interdependencies between related actions or their associated risks are taken into account.
During the design of a new facility or modification of existing facilities, design objectives
are set to optimise exposures of workers and the public.
Dose optimisation is used to limit doses associated with various activities, and dose limits are set
to ensure that desired levels of safety are achieved.
Doses to public are kept ALARA with the application of optimisation for discharges to the
environment and through implementation of a system of Annual Authorised Discharge Quantities
(AADQ).
Workers at mining and mineral processing facilities are monitored at defined intervals and
conditions are continuously reviewed to ensure that doses are kept in accordance with the
requirements of the ALARA programme.
F-4.1.3.
OCCUPATIONAL DOSE CONTROLS
All holders of nuclear authorisations undertake various radiation protection actions to limit the
exposure of workers and ensure compliance with the dose limits. These include: establishing
a radiation protection programme, optimising design of facilities, establishing radiation and
contamination control zones, a work permit system for non-standard tasks and registering of
radiation workers.
The nuclear authorisation holders maintain dose records for workers and projections of public
doses, based on the quantities of effluent released. Doses that are above reference levels
for individual workers are investigated and at higher values interventions occur to limit further
exposure.
In the mining industry a limited number of shafts have registered worker doses above
the annual effective dose limit of 50 mSv/a. In those shafts where the dose limit was exceeded
workers were removed and relocated. The ventilation in these shafts was also improved to
reduce the dose to below 50 mSv/a.
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F-4.1.4.
MEASURES TO PREVENT UNPLANNED/UNCONTROLLED RELEASES
The SSRP and conditions of authorisation stipulate that the principle of defence- in-depth must
be applied in the design and operation of the nuclear installation in accordance with good
engineering and international norms and practice. This includes prevention and mitigation of
accidents, and redundant measures to reduce probability of discharges to the environment. The
degree to which defence-in-depth is applied must take into account the scale of the hazard.
F-4.2.
DISCHARGE CONTROL
In the SSRP provision is made for the control of discharges to the environment.
“The Regulator may, for the purposes of controlling radioactive discharges from a single authorised
action, determine a source-specific annual authorised discharge quantity (AADQ) in the nuclear
authorisation, which must take into account the dose constraint and links to optimisation.”
The term ‘discharge’ is used to refer to the on-going or anticipated releases of radionuclides arising
from the normal operation of an authorized action/facility or a source within an authorized
action/facility. It is a requirement that both discharges to atmosphere and discharges to water
bodies need to be addressed.
Any person applying for an authorisation for the discharge of radioactive effluents must submit
to the NNR the relevant information necessary to support the application. The application must
contain an assessment of the nature, magnitude and likelihood of the exposures attributed to the
discharges and an appropriate safety assessment, including an explanation of how radiological
protection has been optimised and the assessed dose/risk to members of the public from the
discharge of radioactive effluents as a result of normal operations.
The effectiveness of radiation protection measures for each authorized discharge, together with
the potential impact of this discharge on humans and the environment, must also be assessed.
The submission must also address the issues of waste generation and management
interdependences. In this regard, the submission must demonstrate that the generation
of radioactive wastes in terms of activity and volume is kept to the minimum practicable and
that available options for waste disposal are taken into account to ensure that discharge to the
environment is an acceptable option.
Authorised discharge limits will be issued in the form of a document referred to as a ‘discharge
authorisation’. A revised application for a discharge authorisation must be applied for:
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• whenever an increase in discharges or the discharge of a new radionuclides are being
considered; or
• whenever it is identified that a model assumption has been invalidated.
Nuclear authorisation holders are responsible for setting up and implementing the technical and
organizational measures that are necessary for ensuring the protection of the public in relation to
the radioactive discharges for which they are authorized.
F-4.2.1.
DISCHARGE LIMITS AND REGULATORY REPORTING
Discharge authorisations are normally set in terms of annual limits. While these are the primary
limits, shorter-term levels must be set in order to:
• trigger investigations; and
• ensure that the procedure used and the associated conditions and assumptions used to
estimate doses remain valid, (e.g. to prevent significantly higher doses being received
owing to higher than normal discharges in conditions of poor dispersal in the environment).
As an illustration, these levels could be set at 40% of the annual limit for a calendar quarter, 15% of
the annual limit for a calendar month, or 5% of the annual limit for a week, with account taken of
the nature and operation of the source. Although this is not be seen as a breach of the statutory
discharge authorisation, the operator is required to
• notify the regulatory body if the shorter term levels are exceeded;
• state the reasons for their being exceeded; and
• propose mitigatory measures.
In addition to the above, based on the model results, an appropriate set of environmental
investigation/reporting levels must be developed. The site environmental monitoring programme,
must take due account of the predicted discharge impacts and, must serve as a means of verifying
model predictions.
All licensees have NNR approved programmes implemented. Adherence to the requirements is
verified by the NNR through the compliance assurance program.
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Koeberg
Radioactivity in liquid and gaseous discharges from Koeberg during 2010 contributed a projected
total individual dose of 3 . 54 µSv to the hypothetically most exposed public group. The projected
doses as a result of gaseous and liquid discharges were 0.3 9 µSv and 3 . 1 5 µSv respectively,
which is well within the NNR dose constraint of 250 µSv per annum, and meets the ALARA dose
target of 10 µSv, which is applicable for an annual period in which there is one refuelling outage.
Necsa
At Necsa, discharges to both the atmosphere (via several facility stacks) and to a water body
(Crocodile River) are controlled via a set of nuclear license and control documents, to
ensure that the public exposure to radiation is kept as low as reasonably achievable. For the
year 2010 the estimated dose to the maximum exposed member of the public was; 4.1 µSv for
atmospheric discharges and 5.1 µSv for liquid effluent discharges. This resulted in a total public
dose estimate of 9.2 µSv that is 3.47% of the dose constraint of 250 µSv/annum set by the NNR.
Mines
At present source specific AADQ’s are not applied at mining and mineral processing facilities. The
NNR is currently undertaking investigations in this regard and plans to introduce source specific
AADQ’s for mining and mineral processing facilities in the near future.
F-4.3.
UNPLANNED RELEASE OF RADIOACTIVE MATERIALS INTO THE
ENVIRONMENT
The unplanned release of radioactive material into the environment is a reportable event in terms
of the conditions of authorisation. In reporting the event the nuclear authorisation holder
is responsible for investigating the causes of the event and determining appropriate corrective
and preventative actions to be undertaken. The NNRA further provides the NNR with authority
to impose any condition necessary for the rehabilitation of the site or to ensure protection of
persons, property and the environment from nuclear damage.
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F-5
EMERGENCY PREPAREDNESS
Article 25: Emergency preparedness
1. Each Contracting Party shall ensure that before and during operation of a spent fuel or
radioactive waste management facility there are appropriate on-site and, if necessary,
off-site emergency plans. Such emergency plans should be tested at an appropriate
frequency.
2. Each Contracting Party shall take the appropriate steps for the preparation and testing
of emergency plans for its territory insofar as it is likely to be affected in the event of a
radiological emergency at a spent fuel or radioactive waste management facility in the
vicinity of its territory.
F-5.1.
EMERGENCY PLANS
The NNRA requires the establishment of an emergency plan, where the possibility of a nuclear
accident affecting the public may occur. The regulator must ensure that such emergency plans
are effective for the protection of persons should a nuclear accident occur. The emergency plan
includes a description of facilities, training and exercising arrangements, and liaison with off- site
authorities as well as relevant international organizations and emergency preparedness provisions.
Furthermore, the Minister may, on recommendation of the Board of Directors and in consultation
with the relevant municipalities, make regulations on the development surrounding any nuclear
installation to ensure the effective implementation of any applicable emergency plan.
Additionally the conditions of licence require that
a. The licensee must ensure that emergency planning and preparedness processes include
procedures to ensure that all persons, in the employ of the licensee, who have duties in
connection with such processes, are properly trained and instructed in:
(i)
the performance of the processes;
(ii)
the use of any equipment that may be required; and
(iii)
the precautions to be observed.
b. Where emergency planning and preparedness processes require the assistance or cooperation
of, or it is expedient to make use of the services of any person, local authority or any other
body; the licensee must ensure that such persons, local authority or other body are consulted
in the periodic review and update of such processes.
c. The licensee must ensure that all emergency planning and preparedness processes are
exercised and tested at such intervals and at such times and to such extent as the NNR may
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specify or, where the NNR has not so specified, as the licensee considers necessary to ensure
their continued viability.
All facilities have emergency plans to describe the emergency organization, emergency scenarios
(including initiating event, source term and consequences) and actions to control an emergency
(including data to be reported, mitigatory measures and personnel monitoring requirements).
In order to assess the effectiveness of the emergency preparedness and response arrangements
the NNR normally performs audits and arranges a regulatory emergency exercise during which
the response to a given scenario is tested. This testing of the licensee’s emergency preparedness
and response is additional to the self-testing required of licensees.
In terms of other relevant legislation applicable to emergency planning the Disaster Management
Act, Act 57 of 2002 (DMA) was promulgated on 15 January 2003.
The DMA provides for:
• an integrated and coordinated disaster management policy that focuses on preventing or
reducing the risk of disasters, mitigating the severity of disasters, emergency preparedness,
rapid and effective response to disasters, and post- disaster recovery
• the establishment of national, provincial and municipal disaster management centres
• disaster management volunteers
• matters relating to these issues.
The national disaster management framework comprises six key performance areas (KPA’s). Each
KPA is informed by specified objectives and, as required by the Act, key performance indicators
(KPIs) to guide and monitor its implementation.
(i)
KPA 1 focuses on establishing the necessary institutional arrangements for
implementing disaster management within the national, provincial and municipal spheres
of government and describes some of the mechanisms for funding disaster management.
(ii)
KPA 2 addresses the need for disaster risk assessment and monitoring to set
priorities, guide risk reduction action and monitor the effectiveness of our efforts.
(iii) KPA 3 introduces disaster management planning and implementation to inform
developmentally-oriented approaches, plans, programmes and projects that reduce
disaster risks.
(iv) KPA 4 presents implementing priorities concerned with disaster response and
recovery and rehabilitation.
(v)
KPA 5 describes mechanisms for the development of both non-accredited and
accredited education and training for disaster management and associated professions
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and the incorporation of relevant aspects of disaster management in primary and
secondary school curricula. It also addresses priorities and mechanisms for supporting
and developing a coherent and collaborative disaster risk research agenda.
(vi) KPA 6 presents processes for evaluation, monitoring and improvement of disaster
management as envisaged in the implementation of the Act. It introduces a range
of mechanisms for measuring and evaluating compliance with the national disaster
management framework and the Act. These include performance audits, self-assessments,
peer reviews, reviews of significant events and disasters, and rehearsals, simulations,
exercises and drills
When a nuclear accident occurs, the nuclear authorisation holder in question must implement the
emergency plan as approved by the regulator. In terms of the decision-making arrangements
regarding a nuclear accident, the authority to implement on-site protective actions rests with the
nuclear installation emergency controller. In terms of the Disaster Management Act, the off-site
authorities are required to verify and implement off-site protective actions as recommended by
the nuclear authorisation holder in the event of a nuclear accident according to the procedures
laid down in the emergency plan.
In support of the emergency plans, environmental monitoring plans, that provide a baseline for
background radiation and radiological concentrations in various environmental media in the
surrounds of the Pelindaba, Vaalputs and Koeberg sites, have been implemented for the past
few decades. These include air, water (river, dam and borehole), sediment, soil, vegetation,
fish, produce and milk as applicable to the sites. Quarterly and annual reports of the findings
are presented to the NNR.
With regard to mining and minerals processing facilities, although emergency preparedness is not
required from such operations, emergency plans and preparedness arrangements are in place for
all residue disposal facilities and incorporated in the management plans.
F-5.2.
INTERNATIONAL ARRANGEMENTS
South Africa has signed and ratified the following International Conventions that are pertinent to
emergency preparedness:
• Convention on Early Notification of a Nuclear Accident; and
• Convention on Assistance in the case of a Nuclear Accident or Radiological Emergency
No specific agreements have been signed with neighbouring countries on matters relating to
notification in the case of a nuclear emergency or the provision of assistance in such a case.
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F-5.3.
PREPARATION AND TESTING OF EMERGENCY PLANS
Preparedness is achieved by training a specific group of professionals, with a view to enhancing
efficiency in responding to an emergency situation. Those who develop and provide specialist
support services in respect of the licence holder’s emergency response are nuclear professionals
and specially trained personnel. These include Government Technical Advisors from the regulatory
body.
For the other personnel, training courses are developed at a level appropriate to the function
required of the individual. The efficiency of these plans at Koeberg and Necsa is tested by the
NNR every 18-24 months.
F-6
DECOMMISSIONING
Article 26. Decommissioning
Each Contracting Party shall take the appropriate steps to ensure the safety of decommissioning
of a nuclear facility. Such steps shall ensure that:
(i) qualified staff and adequate financial resources are available;
(ii) the provisions of Article 24 with respect to operational radiation protection, discharges
and unplanned and uncontrolled releases are applied;
(iii) the provisions of Article 25 with respect to emergency preparedness are applied; and
(iv) records of information important to decommissioning are kept
F-6.1.
QUALIFIED STAFF AND ADEQUATE FINANCIAL RESOURCES
Decommissioning is regarded as a phase in the life cycle of authorised facilities. Specific
requirements applicable to decommissioning, such as early decommissioning planning,
arrangements to ensure appropriate information management, staffing and financial resources
are covered in regulations and the regulatory framework.
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F-6.2.
REQUIREMENTS DURING DECOMMISSIONING
The SSRP prescribes the requirements for decommissioning of nuclear installations, plants or
equipment having an impact on radiation protection and nuclear safety. The development of a
decommissioning plan must be initiated as part of the prior safety assessment and must proceed
throughout the period of operation of the authorised action. The decommissioning plan must be
submitted to the regulator at its various stages of development and must specify all institutional
controls necessary after termination of the period of responsibility of the holder. The need for
institutional controls must be minimized.
It must be demonstrated to the regulator that sufficient financial resources will be available from
the time of cessation of the operation to the termination of the period of responsibility.
F-6.3.
DECOMMISSIONING AT KOEBERG
Decommissioning of the nuclear installation is currently scheduled for after 2035. Financial
provision for the decommissioning (and also spent fuel management) has continued to be
accumulated on a monthly basis since commercial operation of the installation began in 1984.
The financial provision is reflected in the annual financial statements of the licence holder.
These financial statements are audited in accordance with South African national legislation.
The amount of decommissioning and used fuel provision made each month is determined by
present value future estimation for cash flows in terms of decommissioning financial plans. These
financial plans are reviewed regularly and annually adjusted with the South African inflation rate.
Financial and human resources for the management of low and intermediate level radioactive
waste are part of the normal operations of the nuclear installation and hence included in the
business and financial plans.
F-6.4.
DECOMMISSIONING AT NECSA:
A decommissioning strategy is required for all operational and new facilities. The ability
to decommission a facility is a design parameter. Prior to termination of operations, a final
decommissioning strategy is selected and motivated and a decommissioning plan is submitted
to the NNR for approval. The decommissioning plan shall, as a minimum requirement cover phase
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1 decommissioning activities. Continued decommissioning (phase 2 and 3) shall be determined
depending on the circumstances of each case. An explanation of the decommissioning phases is
provided in Section L Annex7.
The operational requirements for example ventilation and radiation protection programmes
approved in the preceding phase of the project shall be maintained until replaced by an approved
program.
F-6.5.
PROVISIONS WITH RESPECT TO EMERGENCY PREPAREDNESS
Decommissioning is regarded as a phase of authorisation and all the main requirements applicable
to the operational phase are applicable for decommissioning.
F-6.6.
RECORDS OF INFORMATION IMPORTANT TO DECOMMISSIONING
The nuclear authorisation holder is required to maintain a record of the facility history. This record
must include:
• facility description,
•
SHE assessments,
• raw material, product quantities, quantities of normal operational liquid and gaseous
discharges and waste generated
• prevailing radiological condition of the facility and surrounding environment,
• events registers and dose exposure records, and
• the prescribed decommissioning reports.
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SECTION G:
G-1
SAFETY OF SPENT FUEL MANAGEMENT
GENERAL SAFETY REQUIREMENTS
Article 4: General safety requirements
Each Contracting Party shall take the appropriate steps to ensure that at all stages of
spent fuel management; individuals, society and the environment are adequately protected
against radiological hazards.
In so doing, each Contracting Party shall take the appropriate steps to:
(i) ensure that criticality and removal of residual heat generated during spent fuel
management are adequately addressed;
(ii) ensure that the generation of radioactive waste associated with spent fuel management
is kept to the minimum practicable, consistent with the type of fuel cycle policy
adopted;
(iii) take into account interdependencies among the different steps in spent fuel
management;
(iv) provide for effective protection of individuals, society and the environment, by applying
at the national level suitable protective methods as approved by the regulatory body,
in the framework of its national legislation which has due regard to internationally
endorsed criteria and standards;
(v) take into account the biological, chemical and other hazards that may be associated
with spent fuel management;
(vi) strive to avoid actions that impose reasonably predictable impacts on future
generations greater than those permitted for the current generation;
(vii) aim to avoid imposing undue burdens on future generations.
G-1.1.
CRITICALITY AND RESIDUAL HEAT REMOVAL
G-1.1.1.
KOEBERG:
Koeberg only handles and stores spent fuel generated from the two Koeberg reactor units.
Irradiated fuel assemblies and control rods are stored only in designated racks in the storage pool.
These are:
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• high and low density storage racks in the storage pool for standard and cropped
fuel assemblies;
• the control rod rack in the storage pool for burned control rods;
• the high-density racks at koeberg are all lined with boron carbide and the coolant
is mixed with boric acid to ensure sub criticality during storage.
G-1.1.2.
Necsa:
SAFARI-1 Irradiated uranium target plates, fuel assemblies and control rods are stored only in
designated racks in the storage pool. These are:
• Standard and cropped fuel assemblies
• The control rod rack in the storage pool for intact control rods
• The cool-off rack in the reactor pool for Molybdenum target plates.
Special arrangements are made for irradiated fuel that is located in other areas during transfer or
for inspection, testing, and cropping. All fuel transfers are carried out in accordance with the
designated fuel transfer permit procedures and forms.
Safety Precautions for handling Fuel Assemblies: Fuel is handled only under the supervision
of a licensed shift supervisor, assisted by at least two reactor operators, one of which is a licensed
reactor operator. A licensed reactor operator must be in the control room to record every fuel
movement in the control room log book and when fuel is being loaded into or unloaded from the
reactor core. He must also monitor the status of the core nuclear instrumentation during these
activities.
Requirements for Shipment of Fuel: Special arrangements for the shipment of fuel out of the
reactor building (e.g. Shipment of fresh fuel back to the manufacturer for any reason, or shipment
of used fuel for long term storage or final disposal) shall be made only in accordance with the
designated fuel transfer permit procedures and forms. Used fuel is shipped only in a properly
designed and licensed used fuel cask.
Criticality of Fuel in Transit: In order to prevent accidental criticality while handling fuel, no
more than six fuel units, i.e. fuel elements and/or control rods, may be present in any location not
included in the description of designated storage locations.
The Thabana Pipestore is a dry storage facility for used fuel from the SAFARI-1 research reactor.
This facility comprises subsurface sealed stainless steel storage pipes. These pipes are positioned
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in boreholes that are lined with normal borehole lining and cement pipe for possible acid
neutralisation. The pipe openings are shielded with a lead plug and are sealed with an airtight
flange. The pipes are kept under pressure of an inert gas. For security and safety purposes the
facility is enclosed in a shed like structure.
During the design of the Pipestore, used fuel storage facility criticality was taken into consideration.
The operating technical specification limits the acceptance of used fuel at the Pipestore to fuel that
has undergone a cooling period of at least 2 years. A subsurface borehole design was selected for
the dual purpose of shielding and heat transfer
G-1.2.
RADIOACTIVE WASTE MINIMISATION
No waste that is associated with used fuel management is generated at facilities, except for the
components such as end adaptors, cadmium section, lower member end adaptors that are
removed at the SAFARI-1 reactor. These are handled as LILW waste.
G-1.3.
INTERDEPENDENCIES IN SPENT FUEL MANAGEMENT
Used fuel is currently kept in interim storage at the generator’s facilities. The facilities have
been designed so as to retrieve elements at a later stage. No decisions have been made with
respect to processing or disposal. The Radioactive Waste Management Policy and Strategy for
the Republic of South Africa outlines a framework within which these decisions will be made.
As far as reasonably practicable, the effects of future radioactive waste management activities,
particularly disposal, will be taken into account when any one radioactive waste management
activity is being considered.
G-1.4.
PROTECTION OF INDIVIDUALS, SOCIETY AND THE ENVIRONMENT
The SSRP prescribes dose and risk criteria applicable to members of the public and workforce, as
well as general safety principles such as defence-in-depth, ALARA, and conformance to good
engineering practice. The dose criteria, discussed in Article 24, are applied in accordance with
international practice (e.g. ICRP, IAEA). The risk criteria, established by the regulator in the 1970s,
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are based on analysis of risk to society imposed by industry and various natural disasters.
These standards refer directly to the primary concerns of nuclear safety, namely radiological risk to
the public and plant personnel, and are intended to ensure protection of the environment against
radiological hazards.
The applicant is required to submit a safety case which must include documentation relevant to
the demonstration of compliance with the SSRP. The safety case typically includes:
• A Safety Analysis Report (SAR);
• Risk and dose assessment;
• General Operating Rules (GOR);
• SAR/GOR supporting documentation;
• Other licence binding documents;
• Changes to the SAR/GOR and supporting documentation relevant to the particular
application;
• Project management documentation; and
• Safety related programmes applicable during a given licensing stage.
In terms of the NNRA, the NNR issues a nuclear installation licence which holds the licensee
responsible to the above standards as well as to the safety case, which for nuclear installations
includes the plant specific Safety Analysis Report.
Used fuel management is managed as part of the operational process of Koeberg and SAFARI-1.
This implies that the protection of individuals, society and the environment is assessed under
the same criteria applicable to operating conditions.
G-1.5.
BIOLOGICAL, CHEMICAL AND OTHER HAZARDS
It is required that waste characterisation be conducted throughout pre-disposal management
steps. Waste category specific characterisation requirements are specified and cover the
establishment of physical, chemical, biological and radiological properties to determine waste
processing needs and the ultimate suitability of the waste package for storage and disposal.
Waste characterisation data and records are used for verification and quality assurance purposes.
Biological, chemical and other hazards associated with used fuel, are considered in relation to
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radiological hazards. In addition, all facilities regulated by the NNR and RADCON have to comply
with all other relevant legislation.
The storage pipes of the Necsa Pipestore are sealed (kept under pressure of an inert gas to avoid
degradation and monitor for leaks). A risk assessment of the facility was carried out.
G-1.6.
PROTECTION OF FUTURE GENERATIONS
According to the Radioactive Waste Management Policy and Strategy for the Republic of South
Africa, the government will initiate investigations into the best long-term solutions for the
management of used fuel. The process of selecting a site for long-term (HLW) waste management
shall involve a public participation process. The principle of protection of future generations is
embodied in the Radioactive Waste Management Policy and Strategy for the Republic of South
Africa and this principle is discussed in Section H-1.6.
G-1.7.
NO UNDUE BURDENS ON FUTURE GENERATIONS
The Radioactive Waste Management Policy and Strategy for the Republic of South Africa embodies
the principle of no undue burden on future generations. In line with this principle the policy and
strategy regards final disposal as the ultimate step in radioactive waste management, although a
stepwise waste management process is acceptable. Long term storage of certain types of waste
e.g. used fuel, may be regarded as one of the steps in the management process
Investigations shall be conducted within set time frames to consider the various options for safe
management of used fuel and the following options shall be investigated:
• long-term above ground storage in an off-site facility licensed for this purpose;
• reprocessing, conditioning and recycling;
• deep geological disposal; and
• transmutation.
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G-2
EXISTING FACILITIES
Article 5: Existing facilities
Each Contracting Party shall take the appropriate steps to review the safety of any spent fuel
management facility existing at the time the Convention enters into force for that Contracting Party and to ensure that, if necessary, all reasonably practicable improvements are made
to upgrade the safety of such a facility.
G-2.1.
LEGISLATIVE FRAMEWORK:
The conditions of authorisation require the holder of a nuclear installation licence to provide
a safety assessment, including a risk assessment, and to keep the assessment up to date. The
assessment must take into account experience feedback (local and international) in terms of
incidents or emergent safety issues.
G-2.2.
KOEBERG: MAIN RESULTS OF SAFETY ASSESSMENTS PERFORMED
The holder is required by conditions of licence to maintain an up to date plant specific safety
assessment. Koeberg completed a periodic safety re-assessment in 1998. A subsequent periodic
safety review was commenced in 2008 and was completed at the end of 2010.
A World Association of Nuclear Operators (WANO) team, comprising experienced nuclear
professionals from three WANO regions, conducted a peer review at the Koeberg Nuclear Power
Station in November 2008. The purpose of the review was to determine strengths and areas in
which improvements could be made in the operation, maintenance, and support of the nuclear
units at the Koeberg Nuclear Power Station.
As a basis for the review, the team used the Performance Objectives and Criteria for WANO
Peer Reviews; Revision 3 dated January 2005. These were applied and evaluated in light of the
experience of team members and good practices within the industry.
The team spent two weeks in the field observing selected evolutions, including surveillance
testing and normal plant activities.
The following was noted:
• WANO credited Koeberg for the progress that had been made since the last WANO review
of 2006 but also identified gaps in performance in several areas, specifically in the areas of
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Plant Status Controls and Situational Awareness (i.e. conventional safety).
• Whilst these gaps have not resulted in an unacceptable situation as regards nuclear safety,
it has been recognised by Koeberg that a step change in management actions and in the
focus on their resolution is required in order to avoid a repeat Area For Improvement (AFI)
finding in these areas and to bring the station back in line with industry best practice. The
utility has developed action plans to address the areas for improvement.
Modifications implemented at Koeberg
Some of the modifications relevant to this convention, which have resulted in safety
improvements, are:
• re-racking of the used fuel pools with high density fuel storage racks;
• castor x/28 f dry storage casks for interim spent fuel storage;
• re-racking of the used fuel pools with super high density fuel storage racks to accommodate
the full design life of the plant;
• increased used fuel pool cooling;
• upgrade of used fuel pool crane;
• upgrade of control room alarms;
• code repair of stress corrosion cracking on the refuelling water storage tank and pipe
work of the spent fuel pool, containment spray and low head safety injection systems.
Generally modifications have been initiated as a result of various factors such as:
• need for additional used fuel storage capacity;
• international operating experience feedback e.g. TMI initiatives;
• other international sources to improve nuclear safety or the installation’s cost effectiveness;
• potential weaknesses in the design, identified during the safety re- assessment of the
nuclear installation, or resulting from the activities reported under Article 14.
A suite of modifications identified as safety re-alignment projects (CP1) has been identified (EdF
was used as a benchmark). These modifications will be completed by 2011/12 by utilising a
phased approach in terms of implementation.
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G-2.3.
NECSA: INCREASE IN STORAGE CAPACITY OF PIPESTORE
The storage capacity of the Necsa Pipestore used fuel storage facility had to be extended. Before
the design was done, a full review was performed on the existing facility. This included a detailed
assessment on a used storage pipe. This assessment proved that current design was safe and
suitable and no improvements were needed to upgrade the safety of the facility.
G-3
SITING OF PROPOSED FACILITIES
Article 6: Siting of proposed facilities
1. Each Contracting Party shall take the appropriate steps to ensure that procedures are
established and implemented for a proposed spent fuel management facility:
(i)
to evaluate all relevant site-related factors likely to affect the safety of such a
facility during its operating lifetime;
(ii)
to evaluate the likely safety impact of such a facility on individuals, society
and the environment;
(iii)
to make information on the safety of such a facility available to members of the
public;
(iv)
to consult Contracting Parties in the vicinity of such a facility, insofar as they
are likely to be affected by that facility, and provide them, upon their request, with general data relating to the facility to enable them to evaluate the
likely safety impact of the facility upon their territory.
1. In so doing, each Contracting Party shall take the appropriate steps to ensure that such
facilities shall not have unacceptable effects on other Contracting Parties by being sited in accordance with the general safety requirements of Article 4.
G-3.1.
SITE-RELATED FACTORS LIKELY TO AFFECT THE SAFETY
In terms of the NNRA, nuclear authorisation applications are required for the siting of nuclear
installations. The conditions of authorisation require the holder of a nuclear installation licence
to provide a safety assessment, including a risk assessment, and to keep the assessment up to
date. The assessment must take into account experience feedback (local and international) in
terms of incidents or emergent safety issues.
In terms of reviewing the suitability of a specific site, the applicant must submit to the regulator a
site safety report which will sufficiently characterise the site so as to demonstrate that the safety
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standards laid down by the regulatory body could be met in respect of the plant design. Typically
the site safety report should address the following topics: description of site and environs,
population growth and distribution, land-use, adjacent sea–usage, nearby transportation, civil
and industrial facilities, meteorology, oceanography and cooling water supply, impact of natural
hazards, impact of external man made hazards, hydrology, geology and seismology, fresh
water supply, site control measures, emergency services, radioactive effluents, and the ecology of
the surroundings.
Although all these topics need to be supported by up to date validated data, one important
factor in determining the suitability of the site is that the projected population growth and
distribution around the site has to be such to provide the assurance that emergency planning
and preparedness arrangements for the site could be maintained viable throughout the lifetime
of the nuclear installation.
Should the regulatory body conclude that the proposed site is not viable or suitable; an
authorisation will not be granted.
G-3.2.
SAFETY IMPACT OF THE FACILITY
Holders of nuclear authorisations must comply with the requirements of the SSRP. The NNR
requires the holder of an authorisation to provide adequate source term data to demonstrate that
the projected dose to the critical group owing to normal operations and accident conditions of
moderate frequency (1-10–2 per annum) comply with an annual average dose limit of 0.25 mSv
per annum to the critical group.
For accidents of frequency lower than 10-2 per annum, the licence holder is required to calculate
the projected accident source terms in order to demonstrate compliance with the risk criteria
laid down by the regulatory body in terms of maximum individual risk, average population risk
and societal risk.
The NNR has further stipulated limits on urban developments in the vicinity of the installation and
holds regular meetings with the licence holder and the local authorities in this regard. The licence
holder is required to maintain an effective emergency plan. The emergency plan is regularly
exercised by the licence holder and independently by the Regulator (every 18 months to two
years) (as reported under Article 25).
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G-3.3.
PUBLIC ACCESS TO SAFETY RELATED INFORMATION
All used fuel management facilities are considered nuclear installations and in terms of the NNRA,
the holders of nuclear installation licences must establish a public safety information forum
in order to inform the persons living in the municipal area on nuclear safety and radiation safety
matters.
Public Safety Information Forums have been established and frequent meetings are held with the
public living in the area of the nuclear installation in order to inform them on current safety issues.
The public and other interested parties are invited to NNR emergency exercises as observers,
during which time opportunities are given to evaluate the state of emergency preparedness.
In terms of the NNRA, the applicant for a new nuclear installation licence must:
• serve a copy of the application upon every municipality affected by the application and
such other body or person as the chief executive officer determines; and
• publish a copy of the application in the Gazette and two newspapers circulating in the
area of every such municipality.
Any person who may be directly affected by the granting of a nuclear installation or vessel licence
pursuant to an application may make representations to the board, relating to health, safety and
environmental issues connected with the application, within 30 days of the date of publication.
Should the NNR Board be of the view that further public hearings are needed, the Board shall
arrange for such hearings.
Further, in terms of the South African environmental legislation an environmental impact
assessment, which is subject to public participation, must also be performed for all radioactive
waste management facilities.
G-3.4.
CONSULTATION WITH CONTRACTING PARTIES
At present South Africa does not undertake any specific consultation with other contracting parties
regarding new facilities; however any contracting party that may be affected will be included in
the consultation detailed under G-3.3.
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G-3.5.
NO UNACCEPTABLE EFFECTS ON OTHER CONTRACTING PARTIES
When any new project is initiated or when modifications to an existing license is made, which
could have an effect on public safety, the public is invited to participate in the new or revised
application for a license. The potential effect from the project on the public is assessed in terms
of the basic safety requirements specified in the SSRP. After authorisation, the NNR implements a
compliance assurance programme. Feedback is given at the public information forums to the
public and other affected parties.
G-4
DESIGN AND CONSTRUCTION OF FACILITIES
Article 7: Design and construction of facilities
Each Contracting Party shall take the appropriate steps to ensure that:
(i)
the design and construction of a spent fuel management facility provide for suitable
measures to limit possible radiological impacts on individuals, society and the environment, including those from discharges or uncontrolled releases;
(ii)
at the design stage, conceptual plans and, as necessary, technical provisions for the
decommissioning of a spent fuel management facility are taken into account;
(iii)
the technologies incorporated in the design and construction of a spent fuel management facility are supported by experience, testing or analysis.
G-4.1.
LEGISLATION AND LICENSING PROCESS DURING DESIGN AND
CONSTRUCTION
The requirements of the NNRA and the principal safety requirements formulated in the SSRP form
the basis for the stipulation of the regulatory requirements for design and construction of nuclear
installations. These requirements are applicable to all existing and new facilities. Authorisation
to operate a facility is only given after it has been verified by the NNR that the construction was
in accordance with the design.
For Koeberg, where appropriate, the requirements of the vendor country are taken into
consideration and safety and engineering standards, including those relating to design,
manufacturing and construction, are required to be those of countries with acceptable records
of safety.
At Necsa management processes are in place to ensure that all projects, which include the
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modification and the establishment of new facilities, are assessed to determine the Safety, Health,
Environment and Quality (SHEQ) requirements for the internal and external approval of the
project. The requirements include the interpretation of the regulatory framework as applicable to
all the project phases (design to decommissioning) that is then communicated and agreed with
the Regulator.
G-4.2.
DECOMMISSIONING AT THE DESIGN STAGE
In accordance with the provisions of the SSRP, a decommissioning strategy must be submitted
as part of the prior safety assessment for any new facility. NNR requirement document RD-0026
further requires that a decommissioning strategy, consistent with the SSRP and Radioactive
Waste Management Policy and Strategy for the Republic of South Africa, must be submitted
as part of the conceptual decommissioning plan from the design phase and must be updated
throughout the operation of the authorised action as a basis for a detailed decommissioning
plan.
G-4.3.
EXPERIENCE, TESTING AND ANALYSIS
The SSRP requires that
“Installations, equipment or plant requiring nuclear installation licence, nuclear vessel
licence or a certificate of registration and having an impact on radiation or nuclear safety
must be designed, built and operated in accordance with good engineering practice.”
Further, in accordance with the provisions of NNR requirement document RD-0034, Quality and
Safety Management Requirements for Nuclear Installations, the following requirements must be
complied with:
(1)
The conditions for application of the selected codes and standards as prescribed by
the authority which released the code / standard must be fulfilled by the organisations
involved in the process. Any deviations must be justified and presented to the NNR for
acceptance.
(2)
QA measures must be defined and must be compatible with the technical requirements
of the selected codes and standards. The involvement of the licensee in the QA
measures must be commensurate with the safety and quality classification of the SSC.
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(3)
All SSC important to nuclear safety must be designed according to the latest or
applicable approved standards as at the time of licensing of the nuclear installation and
must be accepted by the relevant South African authorities. If no approved standards
are available for a specific application, internationally recognised codes or standards
must be proposed for acceptance. The licensee may also request NNR acceptance of a
specific edition of a code or standard. If possible the SSC should be of a design proven
in previous equivalent applications, and must be consistent with the reliability goals
determined for the respective SSC.
(4)
Where new or innovative design or features are used, the licensee must provide the
results of the investigations on applicability of the codes and standards to the NNR. It
must be demonstrated that the selected codes and standards are fully applicable to
the SSC. In any other case a revised code, standard or specification must be developed
and approved.
(5)
Design and development outputs must contain the information necessary for
verification and validation to pre-determined requirements and/or design criteria.
The licensee must ensure that the outputs must be reviewed against inputs as part of a
design review process to provide objective evidence that the requirements /or design
criteria have been met.
(6)
Validation of the output of the design and development processes must be performed
in a controlled manner to ensure that the resulting product is capable of meeting the
requirements for the specified use.
(7)
Design control procedures must be established for verifying or checking the adequacy
of design and as a basis for the performance of design reviews.
(8)
The verification or checking process must be performed by individuals, departments
or organizational units other than those who have performed the original design.
(9)
The licensee must establish a process for the selection and acceptance of the codes
and standards which must be based on the classification of the SSC and graded
quality assurance measures. The selected codes and standards have to be determined
and justified by the licensee. The justification of a code or standard for an intended
application must be acceptable to the NNR.
(10) The licensee must show to the NNR how the deviations will be incorporated and covered
during the design and licensing process in case of deviations from an existing code or
standard with a potential to result in verification, validation and approval process. The
requirements resulting from such deviations must be implemented in the selection
and implementation process of the codes and standards and the qualification of the
suppliers and the SSC.
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(11) Procedures must be established at suppliers for selecting, and reviewing the suitability
of materials, parts, equipment and processes that are essential to the safety functions
of SSC.
(12) Provisions must be implemented to ensure that quality assurance measures are
included in design specifications and that responsibilities are determined to ensure
that compliance with these measures is controlled and achieved. The requirements
that are essential to quality and to procedural processes must be specified prior to
commencing with the activity to which they relate.
(13) The licensee must ensure that design verification procedures are implemented and
measures are performed within their own organisations and level 1 suppliers (suppliers
assigned responsibility for products of high importance to nuclear safety or having a
direct influence on the safety performance of the nuclear installation) if:
• New safety features for nuclear installations are considered that differ significantly
from proven technology or that use simplified, inherent, passive, or other innovative
means to accomplish their safety functions
• Design changes occur for components of existing nuclear installations
(14) In case of design changes the design verification measures must be commensurate
with those applied to the original design and must be performed based on processes
agreed with the NNR.
(15) Design changes must be controlled as part of a configuration management system.
Design changes affecting the safety functions and occurring after the submission of a
safety case must be submitted to and accepted by the NNR in accordance with agreed
processes.
(16) A test programme must be implemented by the licensee or its suppliers to demonstrate
the safe performance of new safety features. It must be ensured that the safety features
will perform as predicted, to provide sufficient data to validate analytical codes, and
that the effects of systems interactions are acceptable. The test program must include
suitable qualification testing of a prototype simulating the most adverse design
conditions. The test programme must be defined in writing and make provision for
sign-offs as the test programme conditions are met.
Additional guidance in this regard is included in NNR position Paper PP-008, Design Authorisation
Framework.
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G-5
ASSESSMENT OF SAFETY OF FACILITIES
Article 8: Assessment of safety of facilities
Each Contracting Party shall take the appropriate steps to ensure that:
(i)
before construction of a spent fuel management facility, a systematic safety assessment and an environmental assessment appropriate to the hazard presented by
the facility and covering its operating lifetime shall be carried out;
(ii)
before the operation of a spent fuel management facility, updated and detailed
versions of the safety assessment and of the environmental assessment shall be prepared when deemed necessary to complement the assessments referred to in paragraph (i).
G-5.1.
PRIOR SAFETY ASSESSMENT AND ENVIRONMENTAL ASSESSMENT
In accordance with the regulations published in terms of the ECAA and the NEMA an
environmental impact assessment is required for all proposed spent fuel management facilities.
The SSRP requires that:
“Measures to control the risk of nuclear damage to individuals must be determined on the basis
of a prior safety assessment which is suitable and sufficient to identify all significant radiation
hazards and to evaluate the nature and magnitude of the associated risks, with due regard to the
dose and risk limits”
G-5.2.
OPERATION
SAFETY
ASSESSMENTS
ASSESSMENTS
AND
ENVIRONMENTAL
The requirements for lifecycle safety assessments and safety cases are detailed in Section E-2.2.2
of this report.
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G-6
OPERATION OF FACILITIES
Article 9: Operation of facilities
Each Contracting Party shall take the appropriate steps to ensure that:
(i)
the licence to operate a spent fuel management facility is based upon appropriate assessments as specified in Article 8 and is conditional on the completion of a commissioning programme demonstrating that the facility, as constructed, is consistent with
design and safety requirements;
(ii)
operational limits and conditions derived from tests, operational experience and the
assessments, as specified in Article 8, are defined and revised as necessary;
(iii)
operation, maintenance, monitoring, inspection and testing of a spent fuel management facility are conducted in accordance with established procedures;
(iv)
engineering and technical support in all safety-related fields are available throughout
the operating lifetime of a spent fuel management facility;
(v)
incidents significant to safety are reported in a timely manner by the holder of the
licence to the regulatory body;
(vi)
programmes to collect and analyse relevant operating experience are established and
that the results are acted upon, where appropriate;
(vii)
decommissioning plans for a spent fuel management facility are prepared and updated, as necessary, using information obtained during the operating lifetime of that
facility, and are reviewed by the regulatory body
G-6.1.
SAFETY ASSESSMENTS AND SAFETY CASES
The requirements for lifecycle safety assessments and safety cases are detailed in Section E-2.2.2
of this report.
The NNR is charged, by virtue of the provisions of NNRA, to consider all relevant aspects of an
application for a nuclear licence which it may receive and may direct the applicant to furnish it
with such information as may assist it in reaching a decision on the granting or refusal of a nuclear
licence, and the conditions under which such a licence ought to be granted.
The licensing process covers several stages including siting, early site works, construction,
commissioning and operation.
The applicant is required to submit the relevant supporting safety documentation for each phase
which would cover the following:
i.
Credentials as an applicant (e.g. legal, financial and organisational aspects);
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ii.
Licensing and construction schedules;
iii.
Site Safety Report;
iv.
Safety Analysis Report (including plant design);
v.
General Operating Rules covering all operational safety related programmes, covering
commissioning, plant operations, quality assurance, radiation protection, waste
management, maintenance, inspection and testing, emergency planning and physical
security.
A site licence followed by a construction licenses may be issued or optionally a combined
construction licence covering siting may be issued. The construction licence would not be issued
until the first four items listed above have been submitted and reviewed by the regulator, and
relevant inspections conducted. Provisional submissions of general operating rules will generally
be required at this stage as well.
The operating licence will generally constitute a phased process involving several licences issued
in stages. Again these would only be issued once the regulator is satisfied with the submissions
covering the relevant aspects of the general operating rules and additional aspects of the SAR as
necessary, and the relevant inspections and tests have been conducted confirming compliance to
the design.
G-6.2.
OPERATIONAL LIMITS AND CONDITIONS
The conditions of authorisation stipulate that the plant must be operated in accordance with
limits and conditions consistent with the overall safety case, which includes the outcome of the
testing and commissioning programmes.
Further to this, the operating licence holds the applicant to the safety case and relevant operating
rules, which include the processes for maintaining the safety case valid and current, incorporating
experience feedback, and modifications to the plant and the safety related procedures.
G-6.3.
OPERATIONAL PROCEDURES
The conditions of authorisation stipulate that all activities relating to nuclear safety shall be
conducted in accordance with procedures and in accordance with a quality management
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system accepted by the regulator. As referred to in G-6.1 these include operations, maintenance,
monitoring, inspection and testing.
G-6.4.
ENGINEERING AND TECHNICAL SUPPORT
To comply with the conditions of the nuclear authorisation the licence holder needs to have
sufficient resources in order to address the full scope of requirements imposed by the regulatory
body. These are covered by the Quality Assurance requirements referred to in G-6.1. The
Regulator monitors and reports on the organisational aspects including competence and staffing
levels of the nuclear authorisation holders, on an annual basis. Deficiency in engineering or
technical support is directed to the nuclear authorisation holder for rectification.
As regards Koeberg Nuclear Power Station for example, the licence holder has entered into
technical co-operation agreements with Electricité de France to provide additional technical
support as necessary.
G-6.5.
INCIDENT REPORTING
Requirements on incident reporting and corrective actions are specified in the conditions of
licence. The licence holder is also required to maintain a problem management and reporting
system to the satisfaction of the regulatory body.
Koeberg reports nuclear safety significant events to WANO, and the regulatory body reports
events to the IAEA-IRS (Incident Reporting System) and INES reporting systems.
G-6.6.
OPERATING EXPERIENCE FEEDBACK SYSTEM
The holder is required by condition of licence to implement an operating experience feedback
system. The licence requires implementation of the relevant processes for analysis of experience
feedback from the plant and relevant international experience feedback, and corrective action.
For Koeberg the process includes operational experience from Electricité de France, WANO, INPO
and manufacturers.
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G-6.7.
DECOMMISSIONING PLANS
In accordance with the regulations on safety standards and regulatory practices (SSRP),
decommissioning plans are required for all facilities from the design stage through to
decommissioning. The plans must be updated periodically and submitted to the regulator for
approval before actual decommissioning commences.
G-7
DISPOSAL OF SPENT FUEL
Article 10: Disposal of spent fuel
If, pursuant to its own legislative and regulatory framework, a Contracting Party has designated
spent fuel for disposal, the disposal of such spent fuel shall be in accordance with the
obligations of Chapter 3 relating to the disposal of radioactive waste.
In the South African context, the term “used fuel” is used instead of “spent fuel”. Pending the
outcome of current investigations into possible reprocessing of the used fuel to extract radioactive
isotopes for further use, used fuel is not classified as radioactive waste. In view of the above there
are currently no immediate plans for disposal of used fuel.
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SECTION H:
H-1
SAFETY OF RADIOACTIVE WASTE MANAGEMENT
GENERAL SAFETY REQUIREMENTS
Article 11: General safety requirements
Each Contracting Party shall take the appropriate steps to ensure that at all stages of radioactive waste management individuals, society and the environment are adequately protected
against radiological and other hazards.
In so doing, each Contracting Party shall take the appropriate steps to:
(i)
ensure that criticality and removal of residual heat generated during radioactive waste
management are adequately addressed;
(ii)
ensure that the generation of radioactive waste is kept to the minimum practicable;
(iii)
take into account interdependencies among the different steps in radioactive waste
management;
(iv)
provide for effective protection of individuals, society and the environment, by applying at the national level suitable protective methods as approved by the regulatory
body, in the framework of its national legislation which has due regard to internationally endorsed criteria and standards;
(v)
take into account the biological, chemical and other hazards that may be associated
with radioactive waste management;
(vi)
strive to avoid actions that impose reasonably predictable impacts on future generations greater than those permitted for the current generation;
(vii)
aim to avoid imposing undue burdens on future generations.
H-1.1.
CRITICALITY AND RESIDUAL HEAT REMOVAL
In accordance with the legislation and conditions of authorisation a safety case must be submitted
by an applicant to the NNR to obtain a nuclear authorisation. The authorisation is granted when
the NNR has satisfied itself that the applicant has addressed all aspects of safety satisfactorily
and that appropriate control programmes are implemented to deal with issues of concern. The
applicant is required to have a criticality safety program in place for all operations involving uranium
and plutonium (except in instances where the isotopic mass fraction is less than that of natural
uranium) including analysis, verification, and implementation thereof. Effective implementation
of this programme is verified by the NNR.
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NNR guidance related to criticality safety requires that the applicant, in the authorisation
application, should demonstrate that:
(1)An adequate organization with which to implement the criticality safety program is established;
(2)An adequate criticality safety program to ensure safe operation of the facility is established
including an adequate criticality accident alarm system (CAAS);
(3)Adequate controls and limits on parameters relied on to prevent nuclear criticality are
implemented; and
(4)Accident sequences identified in the Criticality Safety Evaluations (CSEs) and documented in
the safety analysis leading to nuclear criticality have been assessed.
The applicant’s implementation of criticality safety technical practices to ensure the safe operation
of the facility are required to be described as part of the submitted safety case. This should include:
(1)The commitment to implement criticality safety controls and limits in accordance with
technical practices as described in the application, by incorporating them into the applicant’s
criticality safety program.
(2)Technical practices, including a description of the management measures that ensure
operability of the CAAS and emergency response procedures.
(3)The technical practices to ensure that limits on controlled parameters have an adequate safety
margin. These practices should include those to ensure that the methods used to develop
criticality safety limits are properly validated.
(4)The technical practices to ensure that sufficient criticality safety controls developed in the
CSEs, and taken up in the safety analysis, are identified for each process.
(5)The areas of review as they relate to criticality safety, with specific reference to
i.
Potential accident sequences that could result in nuclear criticality;
ii.
Specific controls relied on to provide reasonable assurance that an inadvertent
criticality will not occur; and
iii.
A demonstration that the likelihood of failure is sufficiently low so as to demonstrate
compliance with the double contingency principle.
(6)A commitment to prepare and maintain applicable safety basis documentation, which will be
in sufficient detail so that criticality controls and contingency analysis can be reviewed and
inspected by the NNR and applicant.
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H-1.2.
MINIMISATION OF RADIOACTIVE WASTE
The Radioactive Waste Management Policy and Strategy for the Republic of South Africa embodies
waste minimisation as a principle and requires that generation of radioactive waste shall be kept
to the minimum practicable.
Generation of waste must be kept to a minimum in terms of activity and volume by application of
design, operating and decommissioning measures. Wastes are segregated by physical, chemical,
radiological and biological characteristics in order to reduce volumes and facilitate good practice
in radioactive waste management.
The waste management process is regarded as an integrated process that includes waste
generation, predisposal waste processing (pre-treatment, treatment and conditioning), waste
storage, waste transport and waste disposal.
Effective implementation is verified by the NNR.
H-1.3.
INTERDEPENDENCIES IN RADIOACTIVE WASTE MANAGEMENT
The Radioactive Waste Management Policy and Strategy for the Republic of South Africa
embodies the principle that interdependencies among all steps in radioactive waste generation
and management shall be appropriately taken into account.
Interdependencies in the generation and management steps are managed through the preparation
of a facility radioactive and hazardous waste management program and waste management
plans. Requirements are identified during the facility hazard assessment and included in the
integrated safety assessment of the facility. The facility waste management programme identifies
waste streams and endpoints and ensures that waste management and transport steps meet
requirements of the NNR.
Non-conformities in earlier processes (e.g., the predisposal processes) may impact on later processes
(e.g., final disposal). It may not always be possible or effective to rectify such non-conformities in
a retrospective manner. In such a case, an integrated waste management approach is endorsed
through integrated safety, health, environment and quality management practice, which aims
to prevent harmful effects on current and future generations for the total life cycle of radioactive
waste management.
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H-1.4.
PROTECTION OF INDIVIDUALS, SOCIETY AND THE ENVIRONMENT
The NNRA mandates that the NNR provide for protection of persons, property and the environment
against nuclear damage through the establishment of safety standards and regulatory practices.
The NNR has published regulations on safety standards and regulatory practices on 26 April 2006
(SSRP).
In developing its regulations, standards and guidance the NNR takes due account of international
standards and criteria, in particular the safety standards of the IAEA, recommendations from the
ICRP and reports from UNSCEAR.
The NNR also tracks regulatory practices at other regulators and has signed bilateral agreements
for the sharing of information, standards and regulatory practices with a number of international
nuclear regulators including nuclear regulatory bodies in Argentina, Canada, France, Korea, United
Kingdom and United States of America.
South Africa is also a member of the Network of Regulators of Countries with a Small Nuclear
Programme (NERS) and as such, shares experiences, etc. associated with regulators of such
countries.
H-1.5.
BIOLOGICAL, CHEMICAL AND OTHER HAZARDS
The NNR has no specific requirements regarding biological, chemical and other hazards. However,
these are considered in as far as they have a connection with radiological hazards. In addition, all
facilities regulated by the NNR and DOH have to comply with all other legislation with regard to
other types of hazards.
Necsa employs a radioactive waste characterisation process for radiological, chemical, mechanical,
thermal and biological properties of radioactive wastes. These characteristics are used to
categorise the wastes in order to determine the applicable processing technology that will be
used to render the final waste matrix acceptable for packaging, storage and final disposal.
The waste acceptance criteria of the Vaalputs low and intermediate level waste repository further
impose requirements on predisposal operators to record and report all radioactive as well as
hazardous chemical and biological waste constituents. It further prescribes a list of prohibited
waste (e.g. pyrophoric material, hazardous chemicals, gas generating constituents, etc.) that will
not be accepted for final disposal.
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H-1.6.
PROTECTION OF FUTURE GENERATIONS
The protection of future generations is a principle embodied in the Radioactive Waste Management
Policy and Strategy for the Republic of South Africa. In accordance with the policy principles,
radioactive waste shall be managed in such a way that predicted impacts on future generations
will not be greater than relevant levels of impact that are acceptable today.
The SSRP prescribes the NNR dose and risk criteria and applicants for and holders of nuclear
authorisations are required, by means of their submitted safety case documentation, to
demonstrate compliance with the prescribed dose and risk criteria.
In the case of waste disposal, permanent containment and isolation in a repository cannot always
be guaranteed over long time periods. It may be possible that some fraction of the waste inventory
could migrate to the biosphere, potentially giving rise to exposures in future years. Doses to
individuals and populations over long time-scales can only be estimated and the reliability of these
estimates decrease as the time period into the future increases. The Post-Closure Radiological
Safety Assessment for Vaalputs Radioactive Waste Disposal Facility considered various long and
short term intrusion and exposure scenarios and concluded that the dose to the most exposed
individual (inadvertent intrusion) would still be within prescribed limits.
H-1.7.
NO UNDUE BURDEN ON FUTURE GENERATIONS
In accordance with the Radioactive Waste Management Policy and Strategy for the Republic
of South Africa, radioactive waste shall be managed in such a way that will not impose undue
burdens on future generations. South Africa has also adopted the “Polluter Pays Principle”, in that
the financial burden for the management of radioactive waste shall be borne by the generator of
the waste.
In the Republic of South Africa, final disposal is regarded as the ultimate step in the radioactive
waste management process, although a stepwise waste management process is acceptable. Long
term storage of certain types of waste e.g. high level waste, long lived waste and spent sources
may be regarded as one of the steps in the management process.
In practice the following hierarchy of waste management options shall be followed where
practicable:
• waste avoidance and minimisation;
• reuse, reprocessing and recycling;
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• storage;
• conditioning and final disposal.
To provide future generations with freedom of choice and to build confidence, all radioactive waste
disposal options shall provide for a defined period during which retrievability will be possible.
Further, to minimise the burden on future generations, decommissioning and closure of facilities
should be implemented as soon as practicable.
H-2
EXISTING FACILITIES AND PAST PRACTICES
Article 12: Existing facilities and past practices
Each Contracting Party shall in due course take the appropriate steps to review:
(i)
the safety of any radioactive waste management facility existing at the time the
Convention enters into force for that Contracting Party and to ensure that, if necessary,
all reasonably practicable improvements are made to upgrade the safety of such a facility;
(ii)
the results of past practices in order to determine whether any intervention is needed
for reasons of radiation protection bearing in mind that the reduction in detriment
resulting from the reduction in dose should be sufficient to justify the harm and the
costs, including the social costs, of the intervention.
H-2.1.
SAFETY OF EXISTING RADIOACTIVE WASTE MANAGEMENT FACILITIES
In terms of the NNRA, the applicant is required to submit a safety case, which must include
documentation relevant to the demonstration of compliance with the SSRP. Approved, existing
safety cases reflect the current situation of the waste management facility.
In accordance with the SSRP, an operational safety assessment must be performed and
submitted to the Regulator at intervals specified in the nuclear authorisation and which must
be commensurate with the nature of operation and the radiation risk involved. The compliance
assurance programmes of the NNR are established to monitor compliance to the conditions of
authorisation.
As an integral part of the operational safety assessment in addition to the on-going assessment,
which focuses on immediate aspects of installation and procedural modification, a requirement
to undertake a periodic safety re- assessment is also in place. The conditions of authorisation for
nuclear installations require that the licensee establish and implement processes for the periodic
and systematic review and reassessment of safety cases submitted to the regulator.
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H-2.2.
REVIEWING THE RESULTS OF PAST PRACTICES
The waste management facilities at Koeberg, Necsa and Vaalputs comply with safety requirements
laid down by the NNR. The requirements prescribe:
• compliance with a system of justification of facilities/actions;
• compliance with dose and risk limits;
• compliance with dose constraints and annual allowable discharge quantities;
• mandate the use of the ALARA principle;
• require application of the “defence in depth” principle and good engineering practice.
When the Vaalputs facility was developed more than two decades ago, the emphasis was placed
on the performance of natural barriers (e.g., low permeability geo-sphere) rather than engineered
barriers. The initial safety report, the probabilistic safety assessment and the post closure safety
assessment for Vaalputs, have not shown that any optimisation/ improvement of the disposal
concept are required in order to enhance the long term safety performance of the site.
The post closure safety assessment has, however, suggested that the operational safety of the
disposal site can be improved by:
• backfilling and covering disposal trenches more promptly and thereby limiting exposure of
waste packages to environmental agents.
• Limiting the water content in disposed waste packages
These suggestions have been incorporated into operational procedures and the waste acceptance
criteria to improve the safety of the facility.
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H-3
SITING OF PROPOSED FACILITIES
Article 13: Siting of proposed facilities
1. Each Contracting Party shall take the appropriate steps to ensure that procedures are
established and implemented for a proposed radioactive waste management facility:
(i) to evaluate the safety of all relevant site-related factors likely to affect the safety of
such a facility during its operating lifetime as well as that of a disposal facility after
closure;
(ii) to evaluate the likely safety impact of such a facility on individuals, society and
the environment, taking into account possible evolution of the site conditions of
disposal facilities after closure;
(iii) to make information on the safety of such a facility available to members of the
public;
(iv) to consult Contracting Parties in the vicinity of such a facility, insofar as they
are likely to be affected by that facility, and provide them, upon their request, with
general data relating to the facility to enable them to evaluate the likely safety
impact of the facility upon their territory.
2. In so doing, each Contracting Party shall take the appropriate steps to ensure that such
facilities shall not have unacceptable effects on other Contracting Parties by being sited in
accordance with the general safety requirements of Article 11.
H-3.1.
SITE-RELATED SAFETY FACTORS
At this stage, there are no new radioactive waste management facilities proposed for development
and siting in South Africa.
The Department of Environmental Affairs and the NNR require holders of nuclear authorisations
to evaluate all relevant site related factors likely to affect the safety of such a facility during its
operating lifetime as well as that of a disposal facility after its closure. Where a major hazard
installation is located on-site outside of a nuclear installation, a risk assessment has to be
conducted every 5 years and submitted to the Department of Labour (DOL) in terms of the
major hazard installation regulations of the Occupational Health and Safety Act, Act No. 85 of
1993.
In terms of the NNRA, nuclear authorisations are required for the siting of nuclear installations. In
anticipation of applications for new nuclear sites, regulations on siting of new nuclear installations
were published in July 2009, for stakeholders comment.
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The purpose of these Regulations is to establish regulatory requirements pertaining to sites
for new nuclear installations. In developing these regulations the NNR took cognizance on
international standards and practices from sources such as the IAEA and also from relevant nuclear
safety authorities of other countries. The standards and processes applied to the current site of
the nuclear installations, reported below, have to a large extent been taken into account in the
proposed Regulations.
In terms of reviewing the suitability of a specific site, the applicant must submit to the NNR a
site safety report which will sufficiently characterise the site such as to demonstrate that the
safety standards of the NNR could be met in respect of the plant design. Typically the site safety
report would address the following topics: description of site and environs, population growth
and distribution, land-use, adjacent sea–usage (if applicable), nearby transportation, civil and
industrial facilities, meteorology, oceanography and cooling water supply, impact of natural
hazards, impact of external man made hazards, hydrology, geology and seismology, fresh water
supply, site control, emergency services, radioactive effluents, ecology.
Although all these topics need to be supported by up to date validated data, one important
factor in determining the suitability of the site is that the projected population growth and
distribution around the site has to be such as to provide the assurance that emergency planning
and preparedness arrangements for the site could be kept viable throughout the lifetime of the
nuclear installation. Should the NNR conclude that the proposed site is not viable and suitable for
licensing; the applicant will need to consider other alternative sites.
H-3.2.
SAFETY IMPACT AFTER CLOSURE
The Vaalputs National radioactive waste disposal facility is the sole disposal facility in the country.
A post closure safety assessment of the disposal facility has been undertaken. This assessment
was based on the IAEA ISAM methodology and demonstrates that the post closure impacts will
be acceptable in terms of the current dose limits.
A conceptual plan is also in place for the care and maintenance of the Vaalputs site up to 300 years
post closure. See also Sections H-5.2 and H-6.9.
H-3.3.
PUBLIC ACCESS TO INFORMATION
Current regulations require that an environmental impact assessment and a nuclear licence for
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nuclear related projects, be subjected to public participation in the decision-making phases prior
to establishment and operation of the nuclear facility. Detail on this process is provided in Section
G-3.3.
Nuclear installation licenses are made available to the public or anybody visiting a nuclear facility
by displaying the licenses in three languages within accessible areas of the facility building.
Information regarding the safe operation of nuclear facilities is communicated
to interested and affected parties on Safety Information Forums.
See also
Section G-3.3.
H-3.4.
CONSULTATION WITH CONTRACTING PARTIES
The current radioactive waste management facilities pose no impact beyond the borders of
the Republic and therefore neighbouring contracting parties have not been engaged on the
likely impact of radioactive waste facility. Any contracting party that may be affected by the
granting of a new nuclear authorisation for radioactive waste management facility will be
included in the consultation detailed under Section G-3.3.
H-3.5.
NO UNACCEPTABLE EFFECTS ON OTHER CONTRACTING PARTIES
When any new project is initiated or when modifications to an existing license are made, which
could have an effect on public safety, the public is invited to participate in the new or revised
application for a license. The potential effect from the project on the public is assessed in terms
of the safety requirements specified in the SSRP. After authorisation, the NNR implements a
compliance assurance programme. Feedback is given at the public information forums to the
public and other affected parties.
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H-4
DESIGN AND CONSTRUCTION OF FACILITIES
Article 14: Design and construction of facilities
Each Contracting Party shall take the appropriate steps to ensure that:
(i) the design and construction of a radioactive waste management facility provides
for suitable measures to limit possible radiological impacts on individuals, society
and the environment, including those from discharges or uncontrolled releases;
(ii) at the design stage, conceptual plans and, as necessary, technical provisions for the
decommissioning of a radioactive waste management facility other than a disposal
facility are taken into account;
(iii) at the design stage, technical provisions for the closure of a disposal facility
are prepared;
(iv) the technologies incorporated in the design and construction of a radioactive waste
management facility are supported by experience, testing or analysis.
H-4.1.
CONTROL MEASURES FOR DESIGN AND CONSTRUCTION
The requirements of the NNRA and the principal safety requirements formulated in the SSRP form
the basis for the stipulation of the regulatory requirements for design and construction of nuclear
installations.
All projects on the Necsa site follow the project approval process with specific requirements
determined by the categorization of the project in terms of nuclear risk. Before construction
of a nuclear facility, a safety assessment report and an environmental assessment are required. In
the event of construction, the contractor must:
• have a health and safety file which contains the information prescribed in the construction
regulations in terms of the OHS Act, Act No. 85 of 1993 that includes; a Necsa approved
Health and Safety plan that addresses hazards which may impact on individuals, society or
the environment
• must be in good standing with the government compensation fund or a licensed insurer.
The management system of Necsa prescribes the requirements and aspects to be considered in
the safety assessment of each nuclear facility at Necsa, including all waste management, storage
and conditioning facilities.
For Koeberg, all storage facilities have been designed to limit release of radon and dust into the
atmosphere and also to limit the amount of seepage and runoff from the source to the environment.
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H-4.2.
CONCEPTUAL PLANS FOR DECOMMISSIONING AT THE DESIGN STAGE
The SSRP requires that a decommissioning strategy must be submitted as part of the prior safety
assessment and must be updated throughout the operation of the nuclear installation as a basis
for detailed decommissioning planning.
All new projects that are undertaken require that conceptual plans for decommissioning are taken
into account during the design stage.
For nuclear power plants, where appropriate, the requirements of the vendor country are taken
into consideration and safety standards are made reference to in terms of those of the country
with an acceptable safety record.
H-4.3.
TECHNICAL PROVISIONS FOR CLOSURE AT THE DESIGN STAGE
Continued monitoring and environmental surveillance of the Vaalputs site is ensured through the
decommissioning and after care strategy, which is a nuclear license requirement and represents
additional safety control measures that contribute to building confidence in the safe operation
of the repository. A strategy for the decommissioning of all nuclear facilities is required.
H-4.4.
EXPERIENCE, ANALYSIS AND TESTING
The same set of requirements applicable to spent fuel facilities applies to facilities discussed in this
section. (See Section G, and Section E)
For the Vaalputs disposal site, technical and scientific data obtained from monitoring and
measurement results are used to improve mathematical models for safety assessments and also
for confirming the disposal system performance and possible impacts of the waste disposal
operations on the environment.
At Koeberg experienced personnel coming from various disciplines are in place to provide
technical support for the application of new technologies for design and construction.
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H-5
ASSESSMENT OF SAFETY OF FACILITIES
Article 15: Assessment of safety of facilities
Each Contracting Party shall take the appropriate steps to ensure that:
(i) before construction of a radioactive waste management facility, a systematic safety
assessment and an environmental assessment appropriate to the hazard presented
by the facility and covering its operating lifetime shall be carried out;
(ii) in addition, before construction of a disposal facility, a systematic safety assessment
and an environmental assessment for the period following closure shall be carried
out and the results evaluated against the criteria established by the regulatory body;
(iii) before the operation of a radioactive waste management facility, updated and
detailed versions of the safety assessment and of the environmental assessment shall
be prepared when deemed necessary to complement the assessments referred to in
paragraph (i).
H-5.1.
SAFETY AND ENVIRONMENTAL ASSESSMENT BEFORE CONSTRUCTION
In accordance with the environmental legislation any authorisation granted for a nuclear
installation by the Department of Environment Affairs would be conditional on the necessary
nuclear authorisation from the NNR being in place. No authorisation (Record of Decision) is
required for facilities commissioned before September 1997 unless the operational status of the
facility changes.
The NNR requirements for safety assessment are stipulated in the SSRP. The same set of
requirements applicable to spent fuel facilities applies to facilities discussed in this section. (See
Section G, and Section E)
At Necsa, the safety assessment report, the facility operating instructions and the environmental
impact assessment requirements of the facility identified during the project review process
constitutes key elements of the safety case of the waste management facility.
The Vaalputs repository was granted a nuclear license to commence operations in 1986 based on
the Vaalputs National Radioactive Waste Disposal Safety Report. A probabilistic safety assessment
of the Vaalputs operations was conducted in 1996 to assess the probabilities of different event
sequences and failure scenarios and this assessment was incorporated into the nuclear license.
The Post-closure Radiological safety Assessment was reviewed in 2007 and the Operational Safety
Assessment was updated in 2010.
For Koeberg, a safety assessment and environmental impact assessment has been developed and
submitted for approval by the respective regulators. These are reviewed and revised at defined
intervals.
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H-5.2.
POST-CLOSURE SAFETY ASSESSMENT OF A DISPOSAL FACILITY
In accordance with NNR requirements, the post-closure safety performance of the Vaalputs
repository system has subsequently been assessed in 2000 and again in 2007 by means of the
post-closure radiological safety assessments. These assessments showed that the natural barrier
component of the multi- barrier system provided sufficient isolation of the waste disposed of in
the Vaalputs repository. The predicted radiation exposure of the public (critical group) is at levels
considered to be acceptable as required by the national regulatory authorities.
The 2007 post-closure radiological safety assessment of Vaalputs showed that the repository
isolation concept, comprising near surface trenches located in the region above the groundwater
table, provides effective isolation from the biosphere for the duration of the operational and
institutional control period. The institutional control period commences after repository closure
and is envisaged to be three hundred years, given the current operational constraints and source
term.
Safety assessments of Vaalputs have shown that the repository system has characteristics that:
• provide a high level of operational and long-term safety;
• demonstrate compliance with performance standards, thus enhancing public confidence
in the disposal system;
• ensure safety without placing excessive financial burdens on the current and future
generations;
• prevents or substantially delays movement of water or radio-nuclides toward the accessible
environment;
• provides for the safe closure of the facility once all operations have ceased, given that
the necessary after care measures are taken within the institutional control period.
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H-6
OPERATION OF FACILITIES
Article 16: Operation of facilities
Each Contracting Party shall take the appropriate steps to ensure that:
(i)
the licence to operate a radioactive waste management facility is based upon appropriate assessments as specified in Article 15 and is conditional on the completion of a commissioning programme demonstrating that the facility, as constructed, is consistent with design and safety requirements;
(ii)
operational limits and conditions, derived from tests, operational experience and
the assessments as specified in Article 15 are defined and revised as necessary;
(iii)
operation, maintenance, monitoring, inspection and testing of a radioactive waste
management facility are conducted in accordance with established procedures.
For a disposal facility the results thus obtained shall be used to verify and to review
the validity of assumptions made and to update the assessments as specified in
Article 15 for the period after closure;
(iv)
engineering and technical support in all safety-related fields are available throughout the operating lifetime of a radioactive waste management facility;
(v)
procedures for characterization and segregation of radioactive waste are applied;
(vi)
incidents significant to safety are reported in a timely manner by the holder of
the licence to the regulatory body;
(vii)
programmes to collect and analyse relevant operating experience are established and that the results are acted upon, where appropriate;
(viii)
decommissioning plans for a radioactive waste management facility other than a
disposal facility are prepared and updated, as necessary, using information obtained during the operating lifetime of that facility, and are reviewed by the
regulatory body;
(ix)
plans for the closure of a disposal facility are prepared and updated, as necessary,
using information obtained during the operating lifetime of that facility and are
reviewed by the regulatory body.
H-6.1.
ASSESSMENTS AND COMMISSIONING PROGRAMME
The same set of requirements applicable to spent fuel facilities applies to facilities discussed in this
section. (See Section G, and Section E).
For facilities in operation at Necsa facility-specific project commissioning requirements are
documented in the pre-planning phase in accordance with the requirements of the approved
SHEQ system.
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All nuclear facilities, including Vaalputs operate under a nuclear installation licence issued by
the NNR in terms of the NNRA. The repository nuclear installation license (NIL-28) includes
requirements regarding the following:
• risk assessment and compliance with safety criteria;
• modifications and license change requests;
• reporting nuclear occurrences;
• probabilistic safety assessment;
• waste acceptance criteria;
• quality and environmental management system;
• radiological environmental surveillance program;
• radiological control programs;
• control over radioactive effluents;
• design technical specifications;
• emergency planning;
• maintenance program;
• security requirements;
• meteorological program;
• in service inspection and testing program; and
• operational procedures.
H-6.2.
OPERATIONAL LIMITS AND CONDITIONS
Facility specific operating technical specifications (OTS) ensure that safety related systems,
structures and components required for normal operation and emergencies are identified during
risk and safety assessments. The conditions for any abnormal operation allowed must be clearly
understood and documented.
The OTS includes safety limits, limiting safety settings, limiting conditions for operation, surveillance
and maintenance requirements and the administrative controls involved in compliance with these
requirements.
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H-6.3.
THE USE OF ESTABLISHED PROCEDURES
Facility specific in-service inspection and maintenance procedures (ISIP) are intended to ensure
that systems, structures and components required for normal operations or emergencies function
properly. The process is limited to the physical systems, structures and components identified in
the risk assessment as items relied upon for safe operation.
Procedures for operation, maintenance, monitoring, inspection/auditing and testing have been
established and are being implemented by the operator and results thereof are provided to the
regulator during inspections and audits.
H-6.4.
ENGINEERING AND TECHNICAL SUPPORT
The same set of requirements applicable to spent fuel facilities applies to facilities discussed in this
section. (See Section G, and Section E)
The Necsa organisation is structured to ensure the necessary technical and engineering support
is available to facility managers.
For the facilities at Koeberg, each operation has a Senior Manager: Engineering who is responsible
for inspection and maintenance of critical safety components of storage facilities. Further,
technical support is obtained from a competent team of engineers from the Eskom corporate
office for operation of the radioactive waste management facility.
H-6.5.
CHARACTERISATION AND SEGREGATION OF RADIOACTIVE WASTE
Waste is characterised according to the Radioactive Waste Management Policy and Strategy for
the Republic of South Africa. Necsa management system documents provide guidance on the
following topics:
• removal of material from radiological areas (SHEQ-INS-8040);
• clearance of materials from authorised facilities (SHEQ-INS-8110);
• off-site transport of radioactive material or contaminated equipment (SHE-INS-8170);
• quantities for the control of radioactive discharges to the environment from the Pelindaba
site (SHEQ-INS-8240);
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• management of radioactive emissions on the Pelindaba site (SHEQ-INS-8230);
• radiological environmental surveillance requirements for the Pelindaba site and vicinity
(SHEQ-INS-8340);
• management of solid radioactive waste (SHEQ-INS-8360);
• solid radioactive waste classification scheme(SHEQ-INS-8380);
• radioactive waste categorization(SHEQ-INS-8390);
Waste acceptance requirements and criteria and discharge requirements are specified in facility
specific procedures. Facility managers are responsible for waste characterisation. The necessity
for detailed radionuclide characterisation depends in part on the projected dose to the critical
group.
At Koeberg, a waste management procedure is in place for the characterisation and segregation
of waste
NNR requirements document RD-004, Radioactive Waste Management: Mining and Minerals
Processing specifies requirements for facilities dealing with NORM material.
H-6.6.
REPORTING OF INCIDENTS
Necsa’s incident reporting is addressed through the following management system documents:
• implementation of the conventions on the early notification and assistance in the case of
nuclear accidents and radiological emergencies (SHEQ-INS-4143);
• event rating scale (SHEQ-INS-4145);
• categorization and notification of SHEQ related events (SHEQ-INS-4140);
• the Necsa emergency plan (SHEQ-INS-3500);
• notification and reporting to all relevant authorities (SHEQ-INS-4144);
• emergency plan for Necsa, Madibeng and Tshwane to control the off-site impact of Necsa
emergencies (SHEQ-PLN-3500);
• requirements for SHEQ related event investigation (SHEQ-INS-4150);
At Koeberg, an occurrence reporting procedure is in place, which provides for detection,
classification and reporting of reportable incidents within prescribed timeframes.
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H-6.7.
ANALYSIS OF OPERATING EXPERIENCES
The detail reported under Section G-6.6 is also relevant here.
Additionally the licensee management systems provide for:
• ALARA reviews: Detail is provided in Section F-4.12 in response to Article 24.
• Safety Reviews: Safety reviews are conducted routinely on facilities with a frequency
depending on the associated risk and when modifications are made. The purpose of facility
safety reviews are to keep facility personnel alert to process hazards, review operating
procedures, identify equipment or process modifications that could have introduced new
hazards, apply new technology to existing hazards, review the adequacy of inspections
and safety instructions and ensure periodic review of the safety assessment.
H-6.8.
DECOMMISSIONING PLANS
Requirements related to decommissioning are reported in Section F-6.
For the radioactive waste management facilities, decommissioning strategies and plans have been
prepared for each operation and are reviewed and updated every 2 years to take into account
any changes and events that might have occurred.
H-6.9.
CLOSURE PLANS
The Vaalputs post closure engineering design incorporates information obtained during the
operating lifetime of the facility. It forms part of the post-closure assessment of the repository
and provides for:
• a detailed description of the Vaalputs repository as envisaged at the time of closure
• a basis for the assessment of potential closure system performance
• an indication that an integrated decommissioning and closure design has been developed
• evidence that good engineering principles and practises have been followed in the
operation and the closure of the facility and are aimed at optimising the site and disposal
operations with regards to radiological impacts arising from historical disposals.
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H-7
INSTITUTIONAL MEASURES AFTER CLOSURE
Article 17: Institutional measures after closure
Each Contracting Party shall take the appropriate steps to ensure that after closure of
a disposal facility:
(i) records of the location, design and inventory of that facility required by the
regulatory body are preserved;
(ii) active or passive institutional controls such as monitoring or access restrictions are
carried out, if required; and
(iii) if, during any period of active institutional control, an unplanned release of
radioactive materials into the environment is detected, intervention measures are
implemented, if necessary.
H-7.1.
PRESERVATION OF RECORDS
To date no radioactive waste disposal facilities have been closed in the Republic of South Africa.
The SSRP makes provision for a system of record keeping to be implemented by holders of nuclear
authorisations.
Further, the conditions of authorisation require that licensees must:
implement and maintain a document management system to ensure that every document required,
every record made, every authority, consent or approval granted and every directive or certificate
issued in pursuance of these conditions of licence is preserved for 30 years or such other period as the
NNR may approve.
Additionally the NNR maintains a document management system aligned with the requirements
of the National Archives and Records Services.
H-7.2.
INSTITUTIONAL CONTROLS
The institutional control period for the Vaalputs installation commences after repository closure
and is assumed to be 300 years (100 years for active institutional control followed by 200 years
passive institutional control) given the current operational constraints.
The active institutional control measures after closure of the site include the following:
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• measures to ensure that records of the location, design and inventory of the facility are
preserved;
• radiological monitoring of environmental performance;
• patrolling and maintenance of disposal site security fences;
• deterring animal, plant and human intrusion;
• maintaining cover over the waste;
• monitoring of the performance of structures to confirm compliance with the design;
• ensuring proper rehabilitation and plant growth over previously disturbed areas.
In the passive institutional control phase it would clearly be preferable to put in place further
regulatory measures to minimise the likelihood of intrusion into the site that was used for
radioactive waste disposal. The following is regarded as means to achieve this:
• site location on official maps;
• land use restrictions/control;
• use of records;
• use of markers.
H-7.3.
INTERVENTION MEASURES DURING INSTITUTIONAL CONTROL
Where non-conformities with regards to safety performance of the disposal site are detected
within the institutional control period, it is foreseen that these will be corrected on a case-by-case
basis in accordance with the best practise at the time. A ground stability unit is responsible for
monitoring the geological stability of the site.
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SECTION I:
TRANSBOUNDARY MOVEMENT
ARTICLE 27.TRANSBOUNDARY MOVEMENT
1. Each Contracting Party involved in transboundary movement shall take the appropriate steps
to ensure that such movement is undertaken in a manner consistent with the provisions of this
Convention and relevant binding international instruments. In so doing:
(i)
a Contracting Party which is a State of origin shall take the appropriate steps to ensure
that transboundary movement is authorized and takes place only with the prior
notification and consent of the State of destination;
(ii)
transboundary movement through States of transit shall be subject to those
international obligations which are relevant to the particular modes of transport
utilized;
(iii)
a Contracting Party which is a State of destination shall consent to a transboundary
movement only if it has the administrative and technical capacity, as well as the
regulatory structure, needed to manage the spent fuel or the radioactive waste in a
manner consistent with this Convention;
(iv)
a Contracting Party which is a State of origin shall authorize a transboundary movement
only if it can satisfy itself in accordance with the consent of the State of destination that
the requirements of subparagraph (iii) are met prior to transboundary movement;
(v)
a Contracting Party which is a State of origin shall take the appropriate steps to permit
re-entry into its territory, if a transboundary movement is not or cannot be completed in
conformity with this Article, unless an alternative safe arrangement can be made.
2. A Contracting Party shall not licence the shipment of its spent fuel or radioactive waste to a
destination south of latitude 60 degrees South for storage or disposal.
3. Nothing in this Convention prejudices or affects:
(i)
the exercise, by ships and aircraft of all States, of maritime, river and air navigation rights
and freedoms, as provided for in international law;
(ii)
rights of a Contracting Party to which radioactive waste is exported for processing
to return, or provide for the return of, the radioactive waste and other products after
treatment to the State of origin;
(iii) the right of a Contracting Party to export its spent fuel for reprocessing;
(iv) rights of a Contracting Party to which spent fuel is exported for reprocessing to return,
or provide for the return of, radioactive waste and other products resulting from
reprocessing operations to the State of origin.
The National Radioactive Waste Management Policy and Strategy for the Republic of South Africa
prescribes that:
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“No Import or Export of Radioactive Waste: In principle South Africa will neither import nor
export radioactive waste.”
RADCON is mandated for the purposes of the HSA to act as the national competent authority in
connection with the International Atomic Energy Agency’s Regulations for the Safe Transport of
Radioactive Material.
Transport of sealed sources classified as Group IV hazardous substances in terms of the HSA requires
prior authorisation from the Directorate Radiation Control under the Department of Health.
The NNR is mandated for the purposes of the NNRA to act as the national competent authority in
connection with the International Atomic Energy Agency’s Regulations for the Safe Transport of
Radioactive Material
Transport of radioactive material, including radioactive waste, that has activity concentrations
above the exclusion levels specified in the SSRP requires prior authorisation from the NNR.
In accordance with the provisions of section 20(2) of the NNRA:
No vessel which is propelled by nuclear power or which has on board any radioactive material capable
of causing nuclear damage may –
(a)Anchor or sojourn in the territorial waters of the Republic; or
(b)Enter any port of the Republic, except under the authority of a nuclear vessel licence.
The NNR has adopted the IAEA Regulations for the Safe Transport of Radioactive Material (TSR-1) and this is referenced in the conditions of authorisation issued by the NNR. All transport of
radioactive material must comply with the requirements of the IAEA regulations.
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SECTION J:
DISUSED SEALED SOURCES
Article 28: Disused sealed sources
1. Each Contracting Party shall, in the framework of its national law, take the appropriate
steps to ensure that the possession, remanufacturing or disposal of disused sealed
sources takes place in a safe manner.
2. A Contracting Party shall allow for reentry into its territory of disused sealed sources
if, in the framework of its national law, it has accepted that they be returned to a
manufacturer qualified to receive and possess the disused sealed sources.
J-1 FRAMEWORK FOR MANAGEMENT OF DISUSED SEALED SOURCES
J-1.1.
AUTHORISATION OF WORK WITH SEALED SOURCES
All sealed sources inside a nuclear installation fall under the regulatory control of the NNR and
are authorised in terms of the conditions of the Nuclear Installation Licence.
Outside a nuclear installation, sources are controlled as Group IV Hazardous Substances in terms
of regulations under the HSA and are regulated by RADCON.
J-1.2.
APPLICATION OF CONTROL
Control over the possession, remanufacturing and disposal of sealed sources is effected through
a procedure which includes:
• approval of activities by the regulator;
• responsibilities;
• control over production;
• source registers;
• work procedures;
• use of sources at other sites;
• industrial radiography requirements;
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• storage conditions and control;
• labelling of sources and source containers;
• smoke detector control;
• pre-disposal management;
• leak test requirements;
• transport and transfer requirements.
The relevant regulatory authority (NNR or RADCON) is required to be notified in advance of the
production, subdivision, procurement, import, export, transfer and pre-disposal management of
sources.
J-2 RE-ENTRY OF DISUSED SEALED SOURCES
The disposal procedure for sealed sources forms an inherent part of the regulatory procedures.
Each time a sealed source is to be disposed of, a written permission must be obtained from
RADCON. Disused sealed sources are held at the Necsa temporary waste storage site at Pelindaba
or, as is the case with some imported sources, are re-exported to their country of origin.
The procedure for the disposal of sealed sources is as follows:
(i)
authorisation holders who wish to dispose of redundant sealed sources have to apply to
RADCON on the prescribed application form, namely RN525.
(ii)
upon receipt of the application, the applicant’s existing Authority to possess and use
radioactive nuclides is checked to ensure that the source that is applied for appears on the
particular authority. If RADCON is satisfied that everything is in order a separate Authority
for disposal is issued. The authority holder is advised to contact Necsa regarding transport
and delivery arrangements. The Nuclear Liabilities Division at Necsa is then contacted and
provided with the full details of the specific application. After Necsa has taken possession
of the source, RADCON is advised and the holder’s Authority is amended by the removal of
the source from the old Authority and a new one issued.
(iii)
if the source is to be exported to the country of origin (typical for high activity medical
sources) the holder must apply for an export Authority on the prescribed form RN781.
Such Authority is issued if RADCON is satisfied that everything is in order and the authority
holder can then make the necessary arrangements for export.
(iv)
upon confirmation of the export, the particular source is removed from the old Authority
and a new one is issued.
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SECTION K:
K-1
PLANNED ACTIVITIES TO IMPROVE SAFETY
NATIONAL MEASURES
K-1.1.
NUCLEAR ENERGY POLICY
The Nuclear Energy Policy for the Republic of South Africa, published in June 2008, presents a
policy framework within which prospecting, mining, milling and use of nuclear materials as well as
the development and utilisation of nuclear energy for peaceful purposes by South Africa shall take
place. The policy covers the prospecting and mining of uranium ore and any other ores containing
nuclear materials, as well as the entire nuclear fuel cycle as well as focusing on all applications of
nuclear technology for energy generation.
K-1.2.
NATIONAL RADIOACTIVE WASTE DISPOSAL INSTITUTE ACT
The National Radioactive Waste Disposal Institute Act (Act No 53 of 2008) of South Africa was
promulgated in 2008 and applies to all radioactive waste in the Republic of South Africa destined
to be disposed of in an authorized waste disposal facility. The Act further establishes the National
Radioactive Waste Disposal Institute (NRWDI), to be a schedule 3 public entity in terms of the
Public Finance Management Act.
K-1.2.1.
PROVISIONS OF THE ACT
The Act assigns the following functions to the NRWDI:
96
(i)
perform any function that may be assigned to it by the Minister in terms of section
55(2) of the Nuclear Energy Act, 1999, (Act No. 46 of 1999), in relation to radioactive
waste disposal;
(ii)
design and implement disposal solutions for all classes of radioactive waste;
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(iii)
develop radioactive waste acceptance and disposal criteria in compliance with
applicable regulatory, health, safety and environmental requirements and any other
technical and operational requirements;
(iv)
maintain a national radioactive waste database and publish a report on the inventory
and location of all radioactive waste in the Republic at a frequency determined by the
board;
(v)
manage the disposal of any ownerless radioactive waste on behalf of the State, including
the development of radioactive waste management plans for such waste;
(vi)
assist generators of small quantities of radioactive waste in all technical aspects related
to the disposal of such waste;
(vii)
implement any assignments or directives from the Minister regarding radioactive waste
disposal;
(viii)
provide information on all aspects of radioactive waste disposal to the public in general,
living in the vicinity of radioactive waste disposal facilities;
(ix)
co-operate with any person or institution on matters related to the performance of any
duty contemplated in this section falling within the functions; and
(x)
perform any other function necessary to achieve the objects of this Act.
The Institute is governed and controlled by a board of directors that consists of:
• an official of the Department designated by the Minister;
• an official nominated by the Department of Environmental Affairs and Tourism and
appointed by the Minister;
• an official nominated by the Department of Water Affairs and Forestry and appointed by
the Minister;
• an official nominated by the Department of Health and appointed by the Minister;
• not more than five other directors;
• the Chief Executive Officer of the Institute; and
• the Chief Financial Officer of the Institute.
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In terms of the provisions of section 23 of the Act:
(1) Any person who has to dispose of radioactive waste must apply to the chief executive
officer for a radioactive waste disposal certificate in the prescribed format and must
furnish such information as the board may require.
(2) The Chief Executive Officer must assess the information for compliance with the
radioactive waste acceptance and disposal criteria contemplated in section 5(c) and,
subject to the board’s approval, must(a)
refuse an application for a radioactive waste disposal certificate and furnish
the applicant in writing with the reasons for the refusal, in accordance with
the Promotion of Administrative Justice Act; or;
(b)
grant an application for a radioactive waste disposal certificate subject to
such conditions as may be determined in terms of section 24 of the Act.
In terms of the provisions of section 24 of the Act:
(1)The Chief Executive Officer may, subject to subsection (2), impose any condition in any
radioactive waste disposal certificate which is necessary to ensure compliance with the
radioactive waste acceptance and disposal criteria contemplated in section 5(c).
(2)The Chief Executive Officer(a)may, subject to paragraph (c), amend any condition in an existing radioactive waste
disposal certificate;
(b)must notify the person in writing to whom the radioactive waste disposal certificate
was issued of such amendment and the reasons therefore; and
(c)must submit to the board any amendments made to a radioactive waste disposal
certificate in terms of paragraph (a) for ratification at the first meeting of the board
following submission of the amendments.
Section 25 of the Act confers the following responsibilities to Waste Generators:
(1)The generators of radioactive waste are responsible for technical, financial and
administrative management of such waste within the national regulatory framework
at their premises and when such waste is transported to an authorised waste disposal
facility.
(2)The generators of radioactive waste must-
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(a)develop and implement site-specific waste management plans based on
national policy;
(b)provide all relevant information on radioactive waste as required by the chief
executive officer;
(c)demonstrate compliance with any conditions of a radioactive waste disposal
certificate;
(d)provide site access to staff of the Institute for inspection against any conditions
of the radioactive waste disposal certificate.
(3)The generators of radioactive waste remain responsible for all liabilities in connection
with such radioactive waste under their control until such time as the radioactive waste
has been received and accepted in writing by the Institution, following an inspection,
at which time liability shall pass to the Institution.
In terms of section 30 of the Act, with effect from the specified date:
(1)all assets, rights, liabilities, obligations, licences and authorisations of the South
African Nuclear Energy Corporation regarding the Vaalputs National Radioactive Waste
Disposal Facility vest in the Institute; and
(2)the persons who immediately before the specified date were employees of the South
African Nuclear Energy Corporation at the Vaalputs National Radioactive Waste Disposal
Facility, appointed in terms of section 25 of the Nuclear Energy Act, 1999 (Act No. 46 of
1999), must be deemed to be employees of the Institute appointed in terms of section
19(2)
Noting that as a new entity the NRWDI will not immediately comply with all regulatory requirements
of the NNR, the following transitional arrangements are established by the Act:
the South African Nuclear Energy Corporation must continue to maintain the nuclear installation
licence of the Vaalputs National Radioactive Waste Disposal Facility by providing where necessary
services to the Institute using the existing government budget allocations until such time as the Institute
is in a position to take over the functions to the satisfaction of the National Nuclear Regulator.
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K-1.3.
NATIONAL REGULATORY SELF-ASSESSMENT – IAEA PROJECT
The AFRA Project on Self-Assessment of Regulatory Infrastructure for Radiation Safety and
Networking of Regulatory Bodies has been initiated by the IAEA to develop and sustain national
regulatory infrastructures for nuclear and radiation safety on the African continent.
In South Africa, both regulatory bodies, (NNR and RADCON) agreed to participate in the IAEA
AFRA project RAF/9/038 “Promoting Self-Assessment of Regulatory Infrastructures for Safety and
Networking of Regulatory Bodies in Africa”. The South African response, analysis and report writing
phases were conducted over one year, and were completed in December 2010. The outcome of
the Self-Assessment was used to inform the organizational and, particularly the technical division
strategy of the NNR.
The scope of the self-assessment matched the organisational functions. It considered the NNR
goals and objectives, size and scope, competency to conduct self-assessment, weaknesses already
identified during previous self-assessment(s), suggestions and recommendations from external
review or appraisal events, areas of improvement identified during the QMS improvement or
implementation, changes in the NNR’s organisation, activities, management governmental
framework, and stakeholder feedback. IAEA GS-R-1 requirements were used as the first level of
Self-Assessment questions and criteria. The IAEA electronic Self-Assessment Tool (SAT) was used
to facilitate the self-assessment process. The main aspects/modules to be considered for the selfassessment included:
• legislative and Government Responsibilities;
• responsibilities and functions of the Regulatory Body;
• organisation of the Regulatory Body;
• authorisation by the Regulatory Body;
• review and Assessment by the Regulatory Body;
• inspection and Enforcement by the Regulatory Body;
• development of Regulation and Guides of the Regulatory Body;
• management System for the Regulatory Body;
• radioactive Waste management and Decommissioning.
Officials participating in the project were selected to ensure that the preselected focus areas for
self-assessment were represented across the regulatory body. A national train-the-trainer course
on the self-assessment methodology was presented by the IAEA and additional in-house training
workshops were conducted. The three phases of the Self-Assessment project included:
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(i)
Answering Phase where descriptive responses to an agreed self-assessment questionnaire
along with all relevant documentary evidence are provided by a Respondent Team.
(ii)
Analysis of Responses Phase documented comparison of how the answers given
correspond to the criteria used as measures of excellence or compliance, and will identify
the strengths and weaknesses of the regulatory body and its current performance relative
to the assessment criteria.
(iii)
Action Planning Phase, upon completion of the self-assessment analysis phase, a national
action plan was developed by the Senior Management to improve the performance,
effectiveness and efficiency of the regulatory bodies.
K-2
REGULATORS FORUMS
The NNR is a member of NERS (Network of Regulators of Countries with Small Nuclear Programmes)
and as such, shares experiences, etc. associated with regulators of countries having a small nuclear
programme.
The NNR has been actively involved in the establishment of the Forum of Nuclear Regulatory
Bodies in Africa (FNRBA), which was launched in South Africa in March 2009. The main purpose of
the FNRBA is to strengthen the regulatory oversight of nuclear and radiation safety on the African
continent through increased cooperation amongst regulatory bodies.
Further, the NNR has bi-lateral agreements with nuclear safety authorities internationally such
as the French ASN, the US NRC, the UK Health and Safety Executive Nuclear Directorate, the
Argentinean (NBNR) and Korea(KINS). The bilateral agreements serve as a legal mechanism for
information sharing and technical cooperation amongst the parties concerned.
The NNR is represented in the IAEA Commission on Safety Standards (CSS) and the IAEA Safety
Committees (NUSSC, WASSC, TRANSSC and RASSC).
K-3
INTERNATIONAL NUCLEAR REGULATORY CONFERENCE
On behalf of the Government of South Africa, the NNR hosted the 2nd International Conference on
Effective Regulatory Systems, as a follow up to the Moscow conference, which was held in Cape Town
from 14-18 December 2009. The purpose of this conference was to emphasise the importance of
a strong, effective global nuclear safety and security regime and the responsibility that all nuclear
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regulators, operating organizations and vendors have in maintaining it. Conferences of this
nature play a vital role in ensuring that senior nuclear safety and security regulators review issues
important to the global nuclear regulatory regime and to focus on the important role regulators
play in safety and security. A regulatory system is effective when it ensures that a high level of
safety, security and safeguards is maintained by licence holders/operating organizations; when it
takes appropriate actions to prevent the degradation of safety and security; when it takes actions
to promote safety and security improvements; when it performs its regulatory functions in an
independent, transparent, timely and efficient way and it strives for the continuous improvement
of itself and the industry.
The Conference was attended by 345 delegates, of whom more than 75% were international
attendees, and was widely acknowledged as being very successful in achieving the objectives set
for the Conference by the IAEA Programme Committee.
K-4
QUALITY MANAGEMENT SYSTEM
The NNR has initiated a project to review and strengthen its current internal processes with
the objective of implementing a state of the art Integrated Management System (IMS). In
conducting this Project the NNR has taken cognizance of the IAEA guidelines for management
systems, International Management System Standards (e.g. ISO 9001) as well as investigating the
approaches and experiences of nuclear regulatory authorities of other countries such as those
from the NERS regulators network.
As part of this development the NNR has finalized its Management System Manual and mandatory
ISO 9001 procedures. This includes important documented processes for the Development,
Review, Approval, Issuance, Control and Revision of NNR Administrative and Technical Documents,
Records Management, Internal Auditing, Corrective Action, Preventive Action and Management
Review.
Core and support processes were identified, mapped, process owners identified and an approval
matrix established. All required process documentation (Policies and Procedures) have been
identified, some have been established and implemented. Although some policies and procedures
still need to be developed, the Management System (MS) in general has therefore been established.
The NNR has initiated a project to strengthen its current Records Management and Knowledge
Management processes through the implementation of an Electronic Document Management
System (SharePoint Intranet). The Intranet systems design has been completed and the various
Departmental Intranet sites established. Upon completion of the Validation and testing of the
system, data migration and publication of existing / historic documents will be conducted.
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Awareness, buy-in and implementation of the MS requirements and processes are not satisfactory
at all levels of the organisation. A Change Management project will be initiated to ensure effective
implementation and buy in of staff at all levels of the organisation.
K-5
REASSESSMENT FOLLOWING EVENTS AT FUKUSHIMA DAIICHI PLANT
The nuclear accident at the Fukushima Daiichi Nuclear Power Plant has highlighted potential
weaknesses of nuclear plants to withstand extreme scenarios which may not have been initially
analysed in their design. The NNR has in response to the event established a task team in April 2011
with the main objectives to identify the lessons from the accident and to conduct a comprehensive
review of regulatory processes and regulations to determine whether the NNR should strengthen
its regulatory oversight system to ensure continuous safety of operating nuclear installations in
the country.
In this regard, the NNR has directed the Nuclear Operators in South Africa namely Eskom and
the South African Nuclear Energy Corporation (Necsa) to perform safety reassessments on the
Koeberg and Safari nuclear installations respectively. The aim of the safety reassessments is
to identify vulnerabilities in the design basis of the facilities, to evaluate the safety margins for
beyond design events, and to identify necessary modifications, measures and technical features to
be implemented where needed to strengthen defence-in-depth and improve safety of operating
facilities. The safety re-assessments reports from the operators are expected by November 2011,
with the NNR review report expected by March 2012.
The NNR will further review and update, as may be required, its current regulatory standards and
requirements incorporating the lessons learnt from the Fukushima event in line with its principal
nuclear and radiation safety requirements as stipulated in the Safety Standards and Regulatory
Practices, including risk and the principle of ALARA. and will direct, where necessary, the operators
to implement these requirements as well as appropriate measures and/or design features to
improve the safety of existing nuclear installations.
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SECTION L:
ANNEXES
The following Annexes are included in the South African National Report:
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ANNEX 1: Used Fuel Management Facilities
ANNEX 2: Inventory of Used Fuel
ANNEX 3:
Radioactive Waste Management Facilities
ANNEX 4: Inventory of Koeberg Radioactive Waste
ANNEX 5:
Inventory of Radioactive Waste at Necsa Facilities
ANNEX 6: Typical Inventories of Radioactive Waste at NORM Facilities
ANNEX 7:
Necsa Facilities Being Decommissioned
ANNEX 8: Reference to National Laws, Regulations, Requirements and Guides
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ANNEX 1:USED FUEL MANAGEMENT FACILITIES
A1-1 USED FUEL MANAGEMENT FACILITIES AT KOEBERG NUCLEAR POWER PLANT:
Used fuel at Koeberg is stored in two interim waste management facilities, namely the interim wet
waste management facility and the interim dry waste management facility. These are detailed
below:
A1-1.1. INTERIM WET MANAGEMENT FACILITY AT KNPP
Koeberg Nuclear Power Plant (KNPP), see Figure 4, consists
of two 900 MW reactors. Each of the reactor units of KNPP
is served by a used fuel pool (UFP) with a capacity of 1 507
used fuel assembly (UFA) storage spaces. 157 of these spaces
are reserved for emergency core offloads. That makes 1 350
spaces available for spent fuel storage in each pool.
Figure 4: Koeberg Nuclear Power Plant
The KNPP stores UFAs in the used fuel pools (UFPs) on site.
Interim wet management facility at KNPP is made up of
boronated pools at both reactor units, which are designed
for temporary waste management of fresh fuel just
delivered and for cooling and storage of irradiated or used
fuel discharged from the reactor core. Each pool consists of
two regions, namely region 1 for fresh fuel storage and
region 2 used fuel storage.
A1-1.2. INTERIM DRY FUEL MANAGEMENT FACILITY AT KNPP
There are older UFAs with low enrichment (<3%) and low burn-up (<30GWd/t) that were removed
from the pools and transferred to four dry-storage Castor X/28F casks. These casks are stored
in the low level waste building at KNPP. Figure 5 and Figure 6 show pictures of the UFA casks in
storage.
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A1-1
Figure 5: UFA casks in storage at KNPP
Figure
viewof
ofthe
theCastor
Castor
X/28F UFA
Figure0:6:AA side
side view
X/28UFA
caskscasks
A1-2 USED FUEL MANAGEMENT FACILITIES AT NECSA:
Used fuel at the Necsa is stored in two waste storage facilities. The wet waste storage facility,
the reactor pool, is found in the reactor and the dry waste storage facility, the pipestore, is found
outside the reactor on the Necsa Pelindaba site. These facilities are described below:
A1-2.1. THE REACTOR POOL
Storage racks, see Figure 7, are available within part of the reactor pool area and this facility
consists of the following:
12 high density storage racks that can host 24 fuel
elements per rack
control rod racks can host 10 control rods and
low density storage racks (currently not in use but are
kept for back-up in case of capacity problems in the pool).
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A1-2.2. THABANA PIPESTORE
The Thabana Pipestore facility is located on the Pelindaba East site of Necsa. It was built in 1994 for
the dry storage of used fuel from the SAFARI-1 research reactor. The facility has a planned design
lifetime of 50 years.
The storage pipes in the Pipestore are subsurface, inert atmosphere, sealed pipes. Access to the
top of the pipes is limited by the enclosed structure built over the pipes.
In 2007 the storage capacity of the facility was increased. The original design was used when
expanding the facility. The facility currently has 60 storage pipes, giving a total storage capacity
of 1200 fuel elements.
Figure 8: A frontal view of the Thabana Pipestore
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ANNEX 2: INVENTORIES OF USED FUEL
A2-1 INVENTORY OF USED FUEL AT KOEBERG NUCLEAR POWER PLANT:
Table 2: Inventory of used fuel in wet storage at Koeberg
STORAGE
Unit 1
Unit 2
Dry Storage
LOCATION
USED FUEL ASSEMBLIES
Region 1
12
Region 2
872
Sub-total
884
Region 1
51
Region 2
815
Sub-total
866
Castor X/28F casks
112
Total
1882
A2-2 INVENTORY OF USED FUEL AT NECSA, PELINDABA:
Table 3: Inventories of used fuel at Necsa Pelindaba site
STORAGE
Wet storage
Dry storage
Total
108
LOCATION
SPENT FUEL ELEMENTS
USED CONTROL
RODS
Safari-1: High Density Rack
Storage
199
6
Safari-1: Low Density Storage
Rack
1
28
Sub-total
200
34
Thabana pipe storage facility
662
114
862
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ANNEX 3:RADIOACTIVE WASTE MANAGEMENT FACILITIES
A3-1 SOUTH AFICAN NUCLEAR ENERGY CORPORATION (NECSA) PELINDABA SITE
Necsa is a diverse nuclear installation; see Figure 9, with various research and commercial
programmes. It is therefore has a variety of radioactive waste storage facilities in operation.
The radioactive waste generated needs to be isolated from the environment and therefore it
is containerised, characterised, immobilised, treated, conditioned and stored before disposal
can be considered. These waste management actions require the waste to be segregated and
therefore the waste is handled in various locations and stores.
Figure 9: View of the Pelindaba site
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
109
Table 4: Listing of radioactive waste management facilities on the Pelindaba site
PURPOSE
Decontamination of uranium contaminated metals
Future decontamination of UF6 containing
cylinders
Liquid Effluent Treatment
Predisposal operations
NAME
Decontamination services
V-A8
Area 27 Decontamination
Area 27
UF6 cylinder decontamination facility
Area 27
LEMS
P-2400
Oil purification plant
Uranium bearing liquid effluent treatment facility
Volume Reduction Facility
Pel East Pans 1-7
Historic liquid waste evaporation facilities.
(Under evaluation for rehabilitation)
Storage of post reactor test fuel pin related
waste
LILW and VLLW drummed and containerized
solid waste storage facilities (conditioned and
un-conditioned waste)
CaF2 pans
Sub area 40
A8
Area 14 Pelstore
Pelindaba East
Thabana
Beva pans A, B, C & 1-14
Pelindaba west
Cell 3: NTP hotcell complex;
P1701
Pelstore
Area 14
Thabana stores 1-5
Thabana
UF6 cylinder and drum store
Area 21
UF6 Cylinder store
Area 16
Pelindaba East Bus Shed waste drum
store
A-west drum store
Storage of non-clearable decontaminated
metals
LOCATION
Quarantine store
Pelindaba
East
A west
Quarantine camp
Historic disposal trenches. Evaluated for
possible retrieval, or approve as disposal
site
Thabana radioactive waste storage
facility (Trenches)
Historic disposal trenches
P-5100
Metal smelter & cutting room
Test smelter
Area 26
Thabana
Below is a short description of some of the radioactive waste management facilities on the Necsa
Pelindaba site.
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
A3-1.1. PELSTORE
Pelstore forms part of the Area 14 Waste Management Complex, which is located on the Pelindaba
East site of Necsa. The building previously housed the Z Plant Uranium Enrichment Facility. During
the decommissioning of the enrichment facility, all the equipment was removed and the building
was cleaned to remove loose contamination. The facility has been used as a storage area since
2001.
The Pelstore consists of a concrete building and is utilised for the storage of containerised solid
radioactive waste. The facility consists of a smooth concrete floor surface of about 15 600m2.
The purpose of the Pelstore facility is to store containers with solid waste, prior to and after
treatment and conditioning. The storage facility comprises:
• drum repacking and inspection area
• the elevated grid floor storage area
• main container storage area
• various adjacent, separate, smaller and enclosed storage rooms
Waste types of various origins are stored in the facility before being processed or disposed of.
The majority of the waste originated from the previous Necsa nuclear fuel cycle program. Waste
originating from industry, SAFARI-1 research reactor and the medical isotope program are also
stored in the facility. The waste is stored, in dedicated blocks, in such a way that easy access
to the containers can be obtained with the applicable handling equipment and for the purpose
of inspections. Information for each waste container in any of the storage facilities is kept on a
central database. This includes content description, origin, characterisation results, movements
and current position
The Pelstore, see Figure 10, may store up to 104 000 waste containers. The current inventory is
about 75 000 waste containers.
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
111
Figure 10: Section of the Pelstore on Pelindaba site
A3-1.2. THABANA STORES 1-5
This facility, see Figures 11 and 12, consists of five (5) naturally ventilated, corrugated iron sheds
(walls and roofs) each with a concrete floor. The five Thabana stores were built as waste stores in
support of the former Y and Z Enrichment Plants, in the late 1970’s. Waste contained in plastic or
metal drums are stored in this facility. These stores are controlled as radiological areas.
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
Figure 11: Side view of Thabana Store 1
Since their establishment they were only used for the storage of drums containing radioactive
waste. Details of these stores are as follows:
Store 1:
The floor area is 300m2; the height is 3.6m and it has a storage capacity of about
2000 drums.
Stores 2 and 3:
Stores 2 and 3 are two adjacent stores with no separating wall in between.
Store 2 has a total floor area of 400m2, height of 3.6m and Store 3 has a floor area of 500m2, height
of 3.6m and both stores have a storage capacity of about 8000 drums each.
Store 4: The total floor area is 975m2 and the height is 3.6m and it has a storage capacity of about
4500 drums.
Store 5: The total floor area is 110m2 and the height is 3.6m and it has a storage capacity of about
400 drums.
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
113
Figure 12: Thabana Stores 2 and 3
A3-1.3. PELINDABA EAST BUS SHED
This storage facility is situated on the east side of the Pelindaba site next to the Necsa Emergency
Control Centre. The facility was built in the 1980’s for the parking of the then used personnel
transport busses. The bus shed became defunct in the early 1990’s. The facility then was an open
structure with no side walls and only the southern side as a brick wall. The facility was upgraded
by closing all the sides with IBR sheeting. The floor of the facility consists partially of concrete and
partially of tarmac. The roof of the facility comprises IBR sheeting. This area is used as a waste
drum storage facility.
The facility is a naturally ventilated, enclosed structure with overall dimensions of 65m x 29m.
The majority of the facility is used as storage area, but the south eastern corner is utilized for the
Segmented Drum Scanner (SDS) used for waste characterization.
The Bus Shed is used for the storage of medical waste from hospitals, compressed waste historically
treated in the Volume Reduction Facility contained in the 200 ℓ metal drums and other untreated
waste drums.
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
A3-1.4. BUILDING A-WEST DRUM STORE
The Building A-West Drum Storage Facility is situated in the south western corner of the A-building
complex of the Necsa site. The store has a concrete floor of area 2120m2 and an IBR roof and is
used for the storage of uranium contaminated waste contained in drums. It has a storage capacity
for about 5000 drums.
During the operation of the Y Enrichment Plant, this facility served as a Y Plant compressor
rebuilding, maintenance and testing facility that became redundant together with Y Plant in
the early 1990’s. Since about 1996 it was used as a waste drum store for uranium contaminated
alumina gel and other waste originating from the Y and the Z Enrichment Plants.
A3-1.5. AREA 21 STORAGE FACILITY
The Area 21 Storage Facility is a storage facility located on the Pelindaba East site of Necsa. The
facility has a concrete floor which is higher than the outside ground level. The storage facility
is a barn type construction, comprising three rows of concrete pillars where each row supports
a concrete beam. The purpose of the concrete beams is to support the long-travel of two 25 t
overhead cranes
This facility is used for the storage of UF6 cylinders containing UF6 heels from the previous
enrichment and conversion processes, ISO shipping containers filled with contaminated metal
destined for a smelter, and 4 ton concrete drums containing solidified liquids from the isotope
production facility.
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
115
A3-2 VAALPUTS NATIONAL RADIOACTIVE WASTE DISPOSAL FACILITY
The Vaalputs National Radioactive Waste Disposal Facility, see Figure 13, is located in the district of
Kamiesberg in the Northern Cape Province.
Figure 13: An aerial view of the Vaalputs site showing disposal trenches
The introduction of nuclear power in South Africa called for the establishment of a national site
for the disposal of LLW. In 1977, the state mandated a specialist study group to look at waste
management alternatives for the intended commercial nuclear program. The study group
recommended, in 1978, that the state proceed with a program to locate a suitable site for the
disposal of radioactive waste in South Africa.
During 1979 to 1982 a comprehensive site selection program was undertaken in accordance
with criteria that were regarded as internationally acceptable. The Vaalputs site emerged as the
preferred option from the candidate sites and was subsequently acquired in 1983.
Detailed site suitability studies commenced in 1983. A preliminary safety report was compiled and
submitted to the regulatory authority in 1984. The report was approved for building operations
to commence. An intermediate safety report was issued to the regulatory authority in October
1986 according to which Vaalputs was granted a nuclear authorisation to operate. The method of
disposal of radioactive waste at Vaalputs was approved to be shallow land disposal in near surface
trenches a few meters deep.
The Vaalputs buildings include the administrative, operational and maintenance areas. The
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
administrative area consists of a reception/display area, offices, canteen, conference room,
controlled and uncontrolled area change rooms, toilet facilities and a records room. The operational
area consists of a laundry, sample counting room, a waste reception area, a decontamination area,
shielded storage area and a liquid waste solidification area. The maintenance area consists of a
mechanical workshop/vehicle service area, store facilities for components, spares, equipment and
flammable liquids, a store facility for site maintenance equipment and utility sections comprising
of a standby generator, compressed air facility, ventilation facility, fire extinguishing pumps,
electrical sub-station and liquid effluent containment area.
The first revision of the Vaalputs waste acceptance criteria was issued early 1986 and the first
waste shipments from KNPS arrived in November that same year.
Vaalputs is currently authorised for the receipt and shallow land disposal of solid low level waste
originating from Koeberg Nuclear Power Station (KNPS) and the South African Nuclear Energy
Corporation (Necsa).
The waste disposal site comprises the following:
• a securely fenced area 900 m x 1 120 m;
• a 700 m x 500 m area for the disposal trenches;
• an exclusion area, or buffer zone, between the trench area and the fence;
• meteorological monitoring station; and
• covered car ports and storage areas for waste handling machinery and equipment
The operational phase that commenced in November 1986 and, under the current nuclear
programme, is estimated to extend for 50 years up to 2036, which is also the estimated end of the
operational period for the Koeberg Nuclear Power Station. It is also envisaged that Necsa’s waste
and other smaller waste producers’ waste will have been successfully disposed of during this
period. The 50 years expected operational lifetime of the Vaalputs repository is based on current
knowledge and information. Any expansion in the South African nuclear programme resulting in
more waste being sent to Vaalputs over longer time periods would require that the operational
lifetime and post-closure arrangements of Vaalputs be reassessed and redefined accordingly.
The institutional control period commences after repository closure and is assumed to be three
hundred years for the Vaalputs near surface repository given the current operational constraints.
It is envisaged that this phase will be maintained until such time that the results of the final safety
case confirm that the residual impact no longer requires further control of the site. During the
institutional control period, it is possible that the Vaalputs site may continue to be subjected to
regulation, including nuclear licensing. It is also assumed that ownership of the site will remain
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
117
with a South African governmental organisation for the duration of this period.
At the end of the institutional control phase (300 years post-closure) it is envisaged that a final
safety assessment would show that no further monitoring and measuring would be required, that
no further corrective action would be necessary and that the site could be declared safe to the
extent that all controls applicable to a radioactive waste disposal site could be lifted.
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
ANNEX 4:INVENTORIES OF KOEBERG RADIOACTIVE WASTE
Table 5: Inventory of processed low-level waste at Koeberg low level storage building
WANO Volume
Drum Type
Volume (m3)
Capacity (m3)
Concrete Drums
144 784
360 024
1 288 400
Steel Drums
171 920
228 270
244 575
Total
316 704
588 294
1 532 975
(m3)
Volume
this is the volume that these wastes occupy in the drum, i.e. resin and cement combined.
Capacity
this is the actual volume of the waste collected.
WANO volume this is the total volume occupied by the drum, i.e. based on outside dimensions of drum.
Table 6: Inventory of solid radioactive waste at Koeberg low level storage building
Drum
Type
Concentrates (C)
Resins
Filters
Trash
(R)
(F)
(NCW)
Sludge
C1
125
205
-
39
5
C2
-
250
-
1
-
C2F
-
-
55
-
-
C4
-
-
22
-
-
210ℓ metal drum
-
273
-
805
-
Total
125
728
77
845
5
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
119
Table 7: Drumming guidelines at Koeberg Power Station
Filter
Resins
Concentrates
Contact Dose Rate
Radionuclide
Drum Type
< 2 mSv/h
Various
210ℓ metal drum
2 - < 15 mSv/h
C1
15 - < 500 mSv/h
C4
> 500
C2F
Contact Dose Rate
Radionuclide
Drum Type
< 2 mSv/h
Various
210ℓ metal drum
2 < 200 mSv/h
C1
> 200 < 3500 mSv/h
C2
> 3500 mSv/h
C3
Activity (MBq/litre)
Radionuclide
Drum Type
< 92.5
Various
C1
> 92.5 MBq/litre
120
C2
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
ANNEX 5:INVENTORIES OF RADIOACTIVE WASTE AT NECSA
FACILITIES
Table 8: Inventory of radioactive waste at storage facilities on Necsa Pelindaba site
WASTE CLASSIFICATION
LOCATION
VOLUME IN STORAGE
(M3)*
HLW
Cell 3 P-1700
~0.25
LILW-LL
LILW-SL
~ 870
See Annex 3
VLLW
~ 8895
~ 1522
NORM-L
NORM-E
* Volumes are based on waste currently registered at Predisposal operations (Necsa central waste storage
facilities), and exclude waste accumulated at waste generator facilities.
Table 9: Inventory of radioactive waste in Necsa old evaporation pans
WASTE CLASSIFICATION
VLLW
LOCATION
Pel East Pans 1-5
Beva Ponds
ESTIMATED VOLUME IN
STORAGE (M3)
5500
Pel East Pan 6
LILW-SL
CaF2 ponds
7800
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
121
Table 10: Inventory of radioactive waste in Necsa disposal facilities
WASTE CLASSIFICATION
LOCATION
VOLUME IN DISPOSAL (M3)*
Spent fuel
None
HLW
None
LILW-LL
None
LILW-SL
Vaalputs
11579
VLLW
None
NORM-L
None
NORM-E
None
Table 11: Inventory of redundant sealed sources
WASTE CLASSIFICATION /
SOURCE CATEGORY
LOCATION
RADIONUCLIDE
QUANTITY
SAFARI-1 pool
Co-60
157
Co-60
10
Cs-137
1
Area-24 source store
Various
4439
Building P-2400
Unknown
2 containers
1
Area-24 source store
2-5
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
ANNEX 6:TYPICAL INVENTORIES OF RADIOACTIVE WASTE AT NORM
FACILITIES
KLOOF GOLD MINE WASTE INVENTORY
Scrap Metal
SITE
STATUS
METHOD
QUANTITY TONNES
OF STORAGE
1
Kloof
1#
Main Salvage
Yard
Operational
Surface
342
2
Kloof
3#
Main Salvage
Yard
Operational
Surface
290
3
Kloof
4#
Main Salvage
Yard
Operational
Surface
571
4
Kloof
7#
Main Salvage
Yard
Operational
Surface
239
5
Kloof
8#
Main Salvage
Yard
Operational
Surface
191
1633
Total
Tailings Dams
SITE
STATUS
METHOD OF STORAGE
m³
1
Plant
1
Tailings Dam
Operational
Surface
54812300
2
Plant
2
# 1 Tailings
Dam
Operational
Surface
9121347
3
Plant
2
# 2 Tailings
Dam
Operational
Surface
15756410
79690057
Total
Waste Rock Dump
SITE
STATUS
METHOD OF STORAGE
QUANTITY TONNES
1
Kloof
1#
Kloof 1#
Operational
Surface
22073426
2
Kloof
2#
Kloof 2#
Not Operational
Surface
3542129
3
Kloof
4#
Kloof 4#
Operational
Surface
3571652
4
Kloof
7#
Kloof 7#
Operational
Surface
1099539
5
Kloof
8#
Kloof 8#
Operational
Surface
1216842
6
Kloof
10#
Kloof 10#
Not Operational
Surface
3380846
7
Kloof
5#
Kloof 5#
Not Operational
Surface
2293326
Total
37177760
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
123
Timber
SITE
STATUS
METHOD OF STORAGE
QUANTITY TONNES
1
Kloof
1#
Main Salvage
Yard
Operational
Surface
51
2
Kloof
3#
Main Salvage
Yard
Operational
Surface
42
3
Kloof
4#
Main Salvage
Yard
Operational
Surface
33
4
Kloof
7#
Main Salvage
Yard
Operational
Surface
69
5
Kloof
8#
Main Salvage
Yard
Operational
Surface
23
218
Total
All other types of waste (Plastic, etc)
METHOD OF STORAGE
SITE
QUANTITY
TONNES
1
Kloof 1#
Main Salvage Yard
Operational
Surface
4
2
Kloof 3#
Main Salvage Yard
Operational
Surface
5
3
Kloof 4#
Main Salvage Yard
Operational
Surface
3
4
Kloof 7#
Main Salvage Yard
Operational
Surface
8
5
Kloof 8#
Main Salvage Yard
Operational
Surface
3
Total
23
NB: All scrap originating from the respective underground shafts is immediately transported to the
main salvage yard to be sorted and classified. Timber is sorted at the main salvage yard and if i t i s
re-usable it is sent to the stapling plant for re-stapling prior to being returned underground f o r re-use f o r
support purposes.
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
BEATRIX GOLD MINE WASTE
SCRAP Metal
SITE
STATUS
METHOD OF STORAGE
QUANTITY
TONNES
1
Beatrix 1, 2 & 3
Shaft
3 Shaft
Operational
Surface
8
2
Beatrix 1, 2 & 3
Shaft
Salvage Yard
Operational
Surface
107
3
Beatrix 4 Shaft
Salvage Yard
Operational
Surface
11
Total
126
Tailings Dams
SITE
STATUS
METHOD OF
STORAGE
QUANTITY TONNES
1
Beatrix 1, 2 & 3
Shaft
# 1 Tailings Dam
Operational
Surface
67881069
2
Beatrix 1, 2 & 3
Shaft
# 2 Tailings Dam
Operational
Surface
34287567
3
Beatrix 4 Shaft
# 1&2 Tailings
Dam
Operational
Surface
25156591
Total
127325227
Waste Rock Dump
SITE
STATUS
METHOD
OF STORAGE
QUANTITY TONNES
1
Beatrix 1, 2 & 3
Shaft
# 1 Dump
Non-operational
Surface
5395819
2
Beatrix 1, 2 & 3
Shaft
# 2 Dump
Operational
Surface
3164096
3
Beatrix 1, 2 & 3
Shaft
# 3 Dump
Operational
Surface
2995238
4
Beatrix 4 Shaft
# 1 Dump
Non-operational
Surface
4010967
5
Beatrix 4 Shaft
# 2 Dump
Operational
Surface
5210817
Total
20776937686
Timber
SITE
STATUS
METHOD OF
STORAGE
QUANTITY TONNES
1
Beatrix 1, 2 & 3 Shaft
Salvage Yard
Operational
Surface
339
2
Beatrix 4 Shaft
Salvage Yard
Operational
Surface
88
Total
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
427
125
All other types of waste (Plastic, etc)
SITE
1
2
3
STATUS
METHOD OF
STORAGE
QUANTITY
TONNES
Beatrix 1, 2 & 3 Shaft
3 Shaft
Surface
9
Beatrix 1, 2 & 3 Shaft
Salvage Yard
Surface
64
Beatrix 4 Shaft
Salvage Yard
Surface
2
Total
75
NB: All scrap originating from the respective underground shafts are immediately transported to the salvage yards
to be sorted and classified, except for 3 Shaft where some of the scrap is temporarily stored before being moved to
the salvage yard. Timber reported above is mainly old wooden sleepers from underground not yet m o n i t o r e d
and or decontaminated. Uncontaminated pipes, kibbles, etc. used during the shaft sinking process are stored at 3
Shaft but are not classified as radioactive waste.
126
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
SOUTH DEEP GOLD MINE WASTE INVENTORY
Scrap Metal
SITE
STATUS
METHOD
OF STORAGE
QUANTITY
TONNES
1
South Deep Gold Mine
Salvage Yard
Operational
Surface
0
2
South Deep Gold Mine
Gold Plant
Operational
Surface
0
Total
0
Tailings Dams
SITE
STATUS
METHOD OF
STORAGE
m³
1
South Deep Gold Mine
Old Tailings Dam
Operational
Surface
22 450 000
2
South Deep Gold Mine
New Tailings Dam
Operational
Surface
33 425 000
Total
55 875 000
Waste Rock Dump
SITE
STATUS
METHOD OF STORAGE
QUANTITY
TONNES
1
South Deep Gold Mine
South Shaft Rock
Dump
Operational
Surface
3 816 060
2
South Deep Gold Mine
Twin Shaft Rock
Dump
Operational
Surface
1 637 800
Total
5 453 860
All other types of waste (Plastic, Cement, Cement Bricks, Bags etc.):
SITE
1
South Deep Gold Mine
STATUS
Industrial Waste
Dump
Operational
METHOD OF STORAGE
Surface
Total
QUANTITY
TONNES
0
0
NB: No scrap metal is stored on site. Scrap metal generated is continuously released to the scrap recyclers in
possession of Certificates of Registration issued by the NNR.
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
127
DRIEFONTEIN GOLD MINE WASTE INVENTORY
Scrap Metal
SITE
STATUS
METHOD OF STORAGE
QUANTITY
TONNES
1
Driefontein
Masakhane Shaft
Operational
Surface
10
2
Driefontein
Pitseng Shaft
Operational
Surface
5
3
Driefontein
Ya Rona Shaft
Operational
Surface
18
4
Driefontein
Hlanganani Shaft
Operational
Surface
10
5
Driefontein
Bambasinani Shaft
Non-operational
Surface
3
6
Driefontein
Rethabilie Shaft
Non-operational
Surface
2
7
Driefontein
Khomanane Shaft
Operational
Surface
8
8
Driefontein
Ithembalethu Shaft
Non-operational
Surface
8
9
Driefontein
Thabaleng Shaft
Operational
Surface
8
10
Driefontein
Salvage Yard
Operational
Surface
6
Total
78
Tailings Dams
SITE
STATUS
METHOD OF
STORAGE
m³
1
Driefontein
# 1 Tailings Dam
Operational
Surface
30430386
2
Driefontein
# 2 Tailings Dam
Operational
Surface
30997376
3
Driefontein
# 3 Tailings Dam
Non-operational
Surface
32653705
4
Driefontein
# 4 Tailings Dam
Operational
Surface
41904533
5
Driefontein
# 5 Tailings Dam
Non-operational
Surface
19043981
155029981
Total
Waste Rock Dump
SITE
STATUS
METHOD OF STORAGE
QUANTITY TONNES
1
Driefontein
2 Dump
Operational
Surface
283622
2
Driefontein
4 Dump
Operational
Surface
368379
3
Driefontein
5 Dump
Operational
Surface
1036357
4
Driefontein
6 Dump
Operational
Surface
998775
5
Driefontein
7 Dump
Operational
Surface
131952
6
Driefontein
9 Dump
Operational
Surface
1281588
174826
7
Driefontein
10 Dump
Operational
Surface
8
Driefontein
11 Dump
Operational
Surface
3751337
9
Driefontein
12 Dump
Operational
Surface
7991869
10
Driefontein
13 Dump
Operational
Surface
474317
11
Driefontein
14 Dump
Operational
Surface
2266071
Total
18759093
Timber
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
SITE
METHOD OF
STORAGE
STATUS
QUANTITY TONNES
1
Driefontein
Masakhane Shaft
Operational
Surface
33
2
Driefontein
Pitseng Shaft
Operational
Surface
9
3
Driefontein
Ya Rona Shaft
Operational
Surface
25
4
Driefontein
Hlanganani Shaft
Operational
Surface
38
5
Driefontein
Bambasinani Shaft
Non-operational
Surface
20
6
Driefontein
Rethabilie Shaft
Non-operational
Surface
4
7
Driefontein
Khomanane Shaft
Operational
Surface
26
8
Driefontein
Ithembalethu
Shaft
Non-operational
Surface
9
Driefontein
Thabaleng Shaft
Operational
Surface
12
10
Driefontein
Salvage Yard
Operational
Surface
28
Total
12
207
All other types of waste (Plastic, Cement, Cement Bricks, Bags etc.):
SITE
STATUS
METHOD OF
STORAGE
QUANTITY TONNES
1
Driefontein
Masakhane Shaft
Operational
Surface
30
2
Driefontein
Pitseng Shaft
Operational
Surface
16
3
Driefontein
Ya Rona Shaft
Operational
Surface
51
4
Driefontein
Hlanganani Shaft
Operational
Surface
33
5
Driefontein
Bambasinani Shaft
Non-operational
Surface
70
6
Driefontein
Rethabilie Shaft
Non-operational
Surface
7
7
Driefontein
Khomanane Shaft
Operational
Surface
35
8
Driefontein
Ithembalethu
Shaft
Non-operational
Surface
9
Driefontein
Thabaleng Shaft
Operational
Surface
10
Driefontein
Salvage Yard
Operational
Surface
Total
20
18
9
289
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
129
ANGLOGOLD ASHANTI: ERGO OPERATIONS
TYPE OF WASTE / FACILITY NAME
QUANTITY (IN SITU)
UNIT
Brakpan
5.58E+08
t
Daggafontein
2.00E+08
t
4L10
1.73E+05
t
4L11
3.10E+04
t
4L42
2.16E+05
t
4L43
8.60E+05
t
5L19
2.14E+05
t
5L21&22
1.08E+06
t
5L23
3.79E+06
t
5L24
1.33E+05
t
5L25
6.60E+05
t
5L26
5.65E+05
t
5L30
2.31E+05
t
5L5
2.12E+05
t
5L6&7
5.45E+05
t
5L9-12
6.00E+05
t
6L12
7.22E+05
t
6L13
2.02E+06
t
6L3
3.13E+05
t
4L8
2.37E+06
t
5L25
1.60E+05
t
5L27
3.50E+05
t
5L28
2.20E+05
t
5L32
2.20E+05
t
6L13
3.06E+04
t
7L14
2.36E+05
t
7L9
2.16E+05
t
CIL Grit
5.27E+05
t
Category III (Radiation Store)
2.06E+02
t
Semi solids waste (Tailings)
Semi solids waste (Grit & Sand)
130
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
ANGLOGOLD ASHANTI: VAAL RIVER OPERATIONS
TYPE OF WASTE / FACILITY NAME
QUANTITY (IN SITU)
UNIT
West Complex Grass Dam
3.04E+07
t
West Complex No.1
3.96E+07
t
West Complex No.2
1.73E+07
t
West Complex No.3
4.68E+05
t
West Complex No.4
7.32E+06
t
West emergency
1.54E+06
t
Ariston Gully
5.51E+06
t
West Extension
3.50E+07
t
West Complex Abandon
4.46E+06
t
East Complex Dam
7.79E+07
t
South East Extension Dam
2.48E+07
t
South Sulphur Paydam
5.52E+07
t
Mispah Dam + Kop U3O8
5.27E+07
t
WRD 1
1.99E+07
t
WRD 2
9.25E+06
t
WRD 3
5.37E+06
t
WRD 4
5.12E+06
t
WRD5
4.63E+06
t
WRD Great Noligwa
5.93E+06
t
WRD Kopanang
1.53E+07
t
WRD Tau Lekoa
6.63E+06
t
WRD Moab Khotsong
5.99E+06
t
Category III (Radiation Store)
1.70E+02
t
Semi solids waste (Tailings)
Solid (Waste Rock)
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
131
ANGLOGOLD ASHANTI: WEST WITS OPERATIONS
TYPE OF WASTE / FACILITY NAME
QUANTITY (IN SITU)
UNIT
Mponeng
2.35E+07
t
Savuka No.7
5.92E+07
t
Savuka No.5
2.14E+07
t
No.1 (L17&L18)
6.38E+06
t
No.2 (L19)
4.85E+07
t
No.3 (L20)
1.44E+05
t
No.4 (L21)
1.52E+05
t
No.5 (L22)
2.56E+06
t
WRD Savuka R11
5.52E+06
t
WRD Savuka R12
4.64E+05
t
WRD Mponeng
7.44E+06
t
Semi solids waste (Tailings)
Solid (Waste Rock)
132
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
Pamodzi Gold
SITE
STATUS
METHOD OF STORAGE
TONNES
PGFS 9#
Non-operational
Tailings dam
52 110 800
PGFS 9#
Non-operational
Rock dump
4 311 872
PGFS 3#
Non-operational
Rock dump
171 035
PGFS 8#
Non-operational
Rock dump
77 154
PGFS 8#
Non-operational
Rock dump
3 266
PGFS 8#
Non-operational
Rock dump
34 952
PGFS 1#
Non-operational
Rock dump
31 396
PGFS 2#
Non-operational
Rock dump
TOTAL
203 027
56943502
OTHER FACILITIES
SITE
STATUS
METHOD OF STORAGE
TONNES
Richards Bay Minerals
Roast tailings
Operational
Stockpile
5 315 612
MSP tailings
Operational
Stockpile
8 366 564
Operational, exploration
210 litre drums
1 789 362
Reclaiming rock dump
Rock dump
1 371 822
Paddy’s Pad
Paddy’s Pad, Edenburg
Deelkraal
Deelkraal mine
TOTAL
16 483 360
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
133
ANNEX 7:NECSA FACILITIES BEING DECOMMISSIONED
Table 12: Necsa Facilities Being Decommissioned
FACILITY
DESCRIPTION
STATUS
Phase III decommissioning completed
Note: these facilities are not yet removed from regulatory control
Area 20
Redundant Hydrogen recovery facility
Phase 3
Area 28
Redundant development / testing facility
Phase 3
K3 Stores
Redundant SEA storage facility
Phase 3
X4 & X5 Labs
Redundant R & D laboratories
Phase 3
Building BEVA C3/C5
Redundant PWR fuel assembly facility
Phase 3
Building P1700 Contaminated labs
Redundant development laboratories
Phase 3
Building P1900 East
Process development facility
Phase 3
Building P3100
Instrument development facility
Phase 3
YG-Foundry
Redundant alloy development facility
Phase 3
Area 14 Oil basement
Redundant Enrichment plant service
facility
Phase 2
Area 16
Redundant Enrichment plant service
facility
Phase 2
C-building
Redundant Enrichment plant
Phase 2
D-building
Redundant Enrichment plant
Phase 2
J-building
Redundant Development / testing facility
Phase 2
Facilities being decommissioned
P2900
E-building
134
Redundant
Conversion development facility
Redundant Enrichment plant
Phase 2
Phase 2
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
FACILITY
DESCRIPTION
STATUS
P2800 building
Redundant Conversion development
facility
Phase 2
P1500 Contaminated labs
Redundant R & D laboratories
Partial Phase 2
YM-vacuum workshop
Redundant pump servicing facility
Partial Phase 2
P2700A
Redundant Conversion development
facility
Phase 2 decommissioning
in progress
Conversion plant
Redundant Conversion facility
Phase 2 decommissioning
scheduled
Area 74 Labs
Redundant conversion plant laboratories
Phase 2 Scheduled for
2013
P1900 West
Redundant R & D laboratories
Scheduled for reuse
XB-building
Redundant development/testing facility
Phase 2
Area 40
Redundant decontamination facility
Phase 2 scheduled for
2013
Definitions:
Phase 1: Phase 1 decommissioning covers the facility Termination of Operation and the minimum decommissioning
activities such as the removal of inventory to obtain a state of passive safety. This phase is associated with a facilityspecific care and maintenance programme which is developed to be commensurate with acceptable risk.
Phase 2: Phase 2 decommissioning covers continued decommissioning activities for the partial or complete removal
and decontamination of process systems with the aim of restricted re-utilisation of facilities or reducing care and
maintenance requirements. Care and maintenance programmes, which are commensurate with the remaining risk,
are maintained.
Phase 3: Phase 3 decommissioning covers the activities required for the clearance facilities. Activities may range
from final decontamination of facilities to clearance levels, or complete demolition of buildings and removal of all
contaminated materials. Phase 3 is the ultimate end point of decommissioning after which a facility is released or
removed from further regulatory control.
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
135
ANNEX 8:REFERENCE TO NATIONAL
REQUIREMENTS AND GUIDES
Act Number
Department
LAWS,
REGULATIONS,
Act
General
130/1993
DOL
Compensation for Occupational Injuries and Diseases Act
73/1980
DEA
Dumping at Sea Control Act
29/1996
DMR
Mine Health and Safety Act
28/2002
DMR
Mineral and Petroleum Resources Development Act
103/1977
Local
Council:
Hartbeespoort
National Building Regulations and Building Standards Act
40/2004
DOE
National Energy Regulator Act
39/2004
DEA
National Environmental Management: Air Quality Act
National Environmental Management: Waste Act
59/2008
DEA
•
B33/2/121/9/P151:Class H:h disposal site (CaF2 pans)
•
Records of Decision
•
12/9/11/L438/7 – Necsa H:H (sewage industrial and chemical effluent treatment facilities)
102/1980
SAPS
National Key Points Act
93/1996
DOT
National Road Traffic Act
36/1998
DWA
National Water Act
39/1994
SSA
National Strategic Intelligence Act
87/1993
South
African
Council
for NonProliferation of
Weapons
of Mass
Destruction
Non-Proliferation of Weapons of Mass Destruction Act
Occupational Health and Safety Act
85/1993
DOL
•
Major hazard installation Regulations. Government Gazette (GG) 22580 Notice Number (NN) 767 of 24 August 2001.
•
Construction Regulations. GG 25207 NN 1010 of 18 July 2003.
57/1978
DTI
Patent Act
33/2004
SAPS
Protection of Constitutional Democracy Against Terrorist and Related Activities Act
Specific:
Disaster Management Act
57/2002
136
DCG&TA
•
Manual: Joint management of incidents involving chemical or biological agents or
radioactive chemicals GG 28437 NN 143 February 2006
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
Act Number
Department
Act
National Environmental Management Act
107/1998
15/1973
DEA
DOH:
Radiation
Control
•
Environmental Impact Assessment Regulations GG 33306 NN543 18 June 2010 as
amended.
•
Listing notice 1: List of activities and competent authorities identified in terms of section 24(2) and 24D GG 33308 NN 544 as amended
•
Listing notice 2:List of activities and competent authorities identified in terms of section 24(2) and 24D GG 33308 NN 545 as amended
•
Listing notice 3: List of activities and competent authorities identified in terms of section 24(2) and 24D GG 33308 NN 663 as amended
•
IEM Companion to the NEMA Environmental Assessment Regulations (Series 5); Public participation in the EIA process (Series 7); Environmental management framework
(EMF) regulations for 2010 in terms of. NEMA (Series 6). GG 33308 NN 603.
•
Records of decision
•
A24/12/20/1294 Necsa - upgrade of the water and effluent collection and treatment
infrastructure (2009)
•
12/12/20/505 Necsa – extension of the Thabana Pipe Storage facility
Hazardous Substances Act
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
137
Act Number
Department
Act
National Nuclear Regulator Act
· Cooperative agreements concluded i.t.o s6 (2) and published i.t.o s6(4) of the Act
on cooperative governance in respect of the monitoring and control of radioactive
material or exposure to ionizing radiation. GG 31232 NN 759 18 July 2008.
· Regulations in terms of section 7(1)(j) of the Act on the contents of the Annual Public
Report on the Health and Safety related to workers, the public and the environment
related to all sites on which a nuclear installation is situated or on which any action
which is capable of causing nuclear damage is carried out. GG 29050 NN 716 of 28
July 2006.
· NL27 Variation 25 in terms of s 21(1): South African Nuclear Energy Corporation
(Necsa).
· NL28 Variation 3 in terms of s 21(1): Vaalputs National Radioactive Waste Disposal
Facility.
· [Annexure other site licences here]
47/1999
DOE
· Regulations in terms of s 29 (1;2) read in conjunction with s47 of the Act on the
categorization of the various nuclear installations in the republic, the level of financial
security to be provided by holders of nuclear installation licenses in respect of each
of those categories and the manner in which that financial security is to be provided.
GG 26327 NN 581 of 7 May 2004.
· Invitation for the public to comment on proposed draft regulations on the siting of
new nuclear installations in terms of s 36. GG 32349 NN 914 3 July 2009.
· Regulations in terms of s36, read with section 47 of the Act on safety standards and
regulatory practices. GG 28755 NN 388 of 28 April 2006.
· Regulations in terms of s37 (3) (a) of the Act on the keeping of a record of all persons
in a nuclear accident defined area. GG 29078 NN 778 of 4 August 2006.
· Regulations in terms of s38(4) read with s47, of the Act on the development
surrounding any nuclear installation to ensure the effective implementation of any
nuclear emergency plan. GG 26121 NN 287 5 March 2004.
· Regulations in terms of s47 read in conjunction with section 26 (4) of the act on
the establishment of a public safety information forum by the holder of a nuclear
installation license to inform the persons living in the municipal area in respect of
which an emergency plan has been established GG 31403 NN 968 12 September
2008.
· Regulations in terms of s47, read with s21 and 22 of the Act, on the format for
the application for a nuclear installation licence or a certificate of registration or a
certificate of exemption. GG 30585 NN 1219 of 21 December 2007
53/2008
138
DOE
National Radioactive Waste Disposal Institute Act 2008
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
Act Number
Department
Act
Nuclear Energy Act
46/1999
DOE
· Declaration [in terms of section 2] of certain substances, materials and equipment
as restricted material, source material, special nuclear material and nuclear related
equipment and material as indicated in government notice No. 740, Schedules 1,2,3,4
respectively GG 31954 NN 207 27 February 2009.
· Invitation for nominations to the board of the South African Nuclear Energy Corporation (NECSA) [in terms of section 16 of the Act] GG 32212 NN 538
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
139
DEFINITIONS
140
Authorised discharge
Planned and controlled release of radioactive material to the environment in accordance with an authorisation from the regulator.
Authorised disposal/
recycling
Release of waste from nuclear regulatory control in terms of compliance with conditional clearance levels and specific disposal and recycling conditions.
Care and maintenance
Actions such as surveillance, inspection, testing and maintenance to ensure that
facilities are
maintainedin a safe state between decommissioning phases.
Decommissioning
Actions taken at the end of useful life of a facility, other than a repository or disposal facility, in retiring it from service with adequate regard for the health and safety
of workers and members of the public and protection of the environment. Actions
include shutdown, dismantling and decontamination, care and maintenance.
Discharge
A planned and controlled release of radionuclides into the environment. Such
releases should meet all restrictions imposed by the regulatory body.
Disposal
The emplacement of waste in an approved specified facility (for example, near
surface or geological repository.
Geological disposal
Isolation of radioactive waste, using a system of engineered and natural barriers at
depth up to several hundred meters in a geologically stable formation.
High level waste (HLW)
The radioactive liquid containing most of the fission products and actinides originally present in used fuel – which forms the residue from the first solvent extraction
cycle in reprocessing – and some of the associated waste streams.
In-service inspection
A system of planned, usually periodic observations and/or tests performed on
all items relied on for safety (IROFS) in order to detect, characterise and monitor
(as appropriate) any defects and anomalies that could threaten pant safety. ISIP is
part of the maintenance process and may be performed at any time that is considered appropriate, including after failure of IROFS.
Long lived waste (LLW)
Radioactive waste containing long-lived radionuclides having sufficient radiotoxicity in quantities and/or concentrations requiring long-term isolation from the
biosphere. The term “long lived radionuclide’’ refers to half-lives usually greater
than 31 years.
Long and intermediate
level waste (LILW)
Radioactive waste in which the concentration of or quantity of radionuclides above
clearance level established by the regulatory body, but with a radionuclide content
and thermal power below those of HLW. Low and intermediate level wastes are
often separated into short-lived and long-lived wastes. Short-lived wastes may be
disposed of in near surface disposal facilities.
Natural occurring
radioactive material
(NORM)
Material containing no significant amounts of radionuclides other than naturally
occurring radionuclides.
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
Near surface disposal
Disposal of waste, with or without engineered barriers, on or below the ground
surface where the final protective covering is of the order of a few meters thick, or
in caverns a few tens of meters below the Earth’s surface.
Nuclear fuel cycle
All operations associated with the production of nuclear energy, including mining,
milling, processing and enrichment of uranium or thorium; manufacture of nuclear
fuel; operation of nuclear reactor; reprocessing of nuclear fuel; decommissioning;
and any action for radioactive waste management and any research or development action related to any of the foregoing.
Phase 1
Decommissioning
Phase 2
Decommissioning
Phase 3
Decommissioning
Pre-treatment
Regulated
disposal
Covers the facility termination of operation and the minimum decommissioning
activities such as the removal of radioactive inventory to attain a state of passive
safety. Care and maintenance programmes, which are commensurate with the
remaining risk, are maintained.
Covers continued decommissioning for the partial or complete removal and
decontamination of process systems with the aim of restricted re-utilization of
facilities or reducing care and maintenance requirements. Care and maintenance
programmes, which are commensurate with the remaining risk, are maintained.
Phase 3 decommissioning covers the activities that are necessary for the clearance
of facilities. Activities may range from final decontamination of facilities to clearance levels, or complete demolition of buildings and removal of contaminated
material. Phase 3 is the ultimate endpoint of decommissioning after which a
facility is released or removed from further regulatory control.
Any or the entire operation prior to waste treatment, such as: Collection, segregation, chemical adjustment, and decontamination.
Disposal of radioactive waste in a facility licensed by the Regulator for disposal of a
specific waste class.
Processed waste
Waste that undergoes any operation that changes the characteristics of the waste,
including waste pre-treatment, treatment and conditioning.
Repository
A nuclear facility (for example, geological repository) where waste is emplaced for
disposal. Future retrieval of the waste from the repository is not intended.
Reprocessing
A process or operation, the purpose of which is to extract radioactive isotopes from
used fuel for further use.
Used fuel
Nuclear fuel removed from a reactor following irradiation, which is no longer usable
in its present form because of depletion of fissile material, poison build-up or radiation damage.
Spent sources
Sources of which the useful lifetime have lapsed.
Storage
The placement of radioactive waste in a nuclear facility where isolation, environmental protection and human control (for example, monitoring) are provided with
the intent that the waste will be retrieved.
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
141
142
Transportation
Operations and conditions associated with and involved in the movement of
radioactive material by any mode on land, water or air. The terms ‘’transport’’ and
“shipping” are also used.
Treatment
Operations intended to benefit safety and/or economy by changing the characteristics of the waste. Three basic treatment objectives are: volume reduction, removal
of radionuclides from the waste, change of composition. After treatment, waste
may or may not be immobilized to achieve an appropriate waste form.
Unprocessed
waste
As-generated raw material requiring further characterisation and processing before
being regarded as a waste stream.
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
ABBREVIATIONS
ALARA
As Low as Reasonably Achievable
COR
Certificate of Registration
DEA
Department of Environmental Affairs
DOE
Department of Energy
DMR
Department of Mineral Resources
DOH
Department of Health
DOL
Department of Labour
EIA
Environmental Impact Assessment
HSE
Health Safety and Environment
IAEA
International Atomic Energy Agency
IROFS
Items Relied on For Safety
ISIP
In-service Inspection Process
Joint Convention
Joint Convention on the Safety of Spent Fuel Management and on the Safety
of Radioactive Waste Management
KNPS
Koeberg Nuclear Power Station
LILW
Low and intermediate level radioactive waste
LILW (SL)
Low and intermediate level radioactive waste (Short lived)
Necsa
South African Nuclear Energy Corporation
NIL
Nuclear installation Licence
NLM
Nuclear Liabilities Management, a division of Necsa
NNR
National Nuclear Regulator
NNRA
National Nuclear Regulator Act, Act No 47 of 1999
NORM
Natural Occurring Radioactive Material
NRWDI
National Radioactive Waste Disposal Institute
OHS
Occupational Health and Safety
OTS
Operating Technical Specification
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
143
144
PMC
Spent fuel pool bridge Eskom
PSIF
Public Safety Information Forum
PWR
Pressure water reactor
QA
Quality Assurance
RCCA’S
Rod cluster control assembly
SSRP
Safety Standards and Regulatory Practices in accordance with section 36 of
the National Nuclear Regulator Act, No 47 of 1999
VCF
Vaalputs Communication Forum
Vaalputs
Vaalputs National Radioactive Waste Disposal Facility located in the magisterial district of Namaqualand in the Northern Cape Province.
WANO
World Association of Nuclear Operators
SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
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SECOND SOUTH AFRICAN NATIONAL REPORT ON COMPLIANCE TO OBLIGATIONS UNDER THE JOINT CONVENTION
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