Draft Safety Case for the Management of Disused Sealed Radioactive Sources in Tunisia NLM-REP-14/197 Rev 1 Date: 2014-12-03 Prepared by: R Swart Nuclear Liabilities Management Necsa P.O. Box 582 Pretoria, 0001 South Africa Form No.: NLM-DIV-FORM-00-002 Rev: 03 REPORT No.: NLM-REP-14/197 Rev 2 DATE: 3 December 2014 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA TITLE: 1.0 AUTHORIZATION NAME 1.1 SIGNED PREPARED R Swart REVIEWED L Hordijk APPROVED GR Liebenberg DATE DISTRIBUTION NO. 1 NAME NAME NO. 8 15 9 16 3 10 17 4 11 18 5 12 19 6 13 20 7 14 21 2 NLM QA Records NO. IAEA * = Distributed via E-mail NAME This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 3 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 1.2 REVISIONS Revision number 0 1 2 Reason for change First issue Revised following review done with CNRP and CNSTN personnel during IAEA mission 13-17 October 2014 Revision based on Morocco SC review and additional comments Preparer R Swart L Hordijk L Hordijk This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 4 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 1.3 CONTENTS 1.0 AUTHORIZATION ....................................................................................................... 2 1.1 DISTRIBUTION ........................................................................................................... 2 1.2 REVISIONS ................................................................................................................. 3 1.3 CONTENTS ................................................................................................................. 4 2.0 PURPOSE ................................................................................................................... 7 3.0 SCOPE ........................................................................................................................ 7 4.0 REFERENCES ............................................................................................................ 8 5.0 ABBREVIATIONS ........................................................................................................ 8 6.0 DSRS MANAGEMENT DESCRIPTION IN TUNISIA .................................................. 8 6.1 LEGISLATION AND REGULATIONS RELATING TO THE MANAGEMENT OF DSRS IN TUNISIA .................................................................................................................. 8 6.2 REGULATORY BODY ............................................................................................... 10 6.3 NATIONAL SAFETY CRITERIA .................................................................................11 6.4 WASTE OPERATOR ................................................................................................. 12 7.0 GENERIC ASSESSMENT CONTEXT ...................................................................... 13 7.1 PURPOSE OF THE SAFETY CASE ......................................................................... 13 7.2 SCOPE OF THE SAFETY CASE .............................................................................. 14 7.3 DEMONSTRATION OF SAFETY .............................................................................. 15 7.4 GRADED APPROACH .............................................................................................. 18 7.5 SAFETY STRATEGY ................................................................................................ 18 8.0 FACILITY AND PROCESS DESCRIPTION .............................................................. 19 8.1 SITE CONDITIONS AND FACILITY DESCRIPTION ................................................ 20 8.2 PROPOSED FACILITY OPERATION ....................................................................... 28 8.3 DSRS INVENTORY................................................................................................... 31 9.0 SAFETY ASSESSMENT ........................................................................................... 31 9.1 SAFETY ASSESSMENT CONTEXT ......................................................................... 31 9.2 SAFETY ASSESSMENT ENDPOINTS ..................................................................... 35 9.3 DEVELOPMENT OF SCENARIOS ........................................................................... 35 9.4 DATA USED AND ASSUMPTIONS MADE FOR THE SAFETY ASSESSMENT ...... 38 10.0 SAFETY ASSESSMENT ........................................................................................... 40 10.1 BASIC ENGINEERING ANALYSES .......................................................................... 40 10.2 QUANTITATIVE DETERMINISTIC ASSESSMENT OF WORKER DOSE................ 43 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. 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No.: NLM-REP-14/197 Rev 2 Page No.: Page 5 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 10.3 DETERMINISTIC ASSESSMENT OF WORKER AND PUBLIC DOSE FOR ANTICIPATED OPERATIONAL OCCURRENCES: .................................................. 47 10.4 THE FOLLOWING OTHER ACCIDENT SCENARIOS WILL BE CONSIDERED IN THE TUNISIAN SAFETY ASSESSMENT: ................................................................ 48 10.5 COMPARATIVE DOSE ASSESSMENT: SAFRAN .................................................... 50 10.6 OPTIMIZATION OF PROTECTION: ASSESSMENT ................................................ 50 10.7 NON-RADIOLOGICAL HAZARD ASSESSMENT ..................................................... 52 10.8 ASSESSMENT OF THE IMPLEMENTED WASTE MANAGEMENT PRACTICE..... 53 10.9 MANAGEMENT SYSTEM ASSESSMENT ............................................................... 54 10.10 ASSESSMENT OF UNCERTAINTIES ...................................................................... 55 10.11 ASSESSMENT OF POSSIBLE PUBLIC EXPOSURES ........................................... 56 10.12 ASSESSMENT OF POSSIBLE ENVIRONMENTAL PATHWAYS ............................. 56 10.13 WASTE MANAGEMENT ........................................................................................... 57 11.0 HUMAN RESOURCES ............................................................................................. 57 12.0 IDENTIFICATION OF FACILITY SPECIFIC LIMITS AND CONDITIONS ................. 58 13.0 INTEGRATION OF SAFETY ARGUMENTS ............................................................. 59 13.1 FACILITY DESIGN AND ENGINEERING ................................................................. 59 13.2 FACILITY OPERATION ............................................................................................. 59 13.3 OPTIMIZATION OF PROTECTION .......................................................................... 59 13.4 WASTE MANAGEMENT PRACTISE ........................................................................ 60 13.5 INTEGRATED MANAGEMENT SYSTEM ................................................................. 60 13.6 UNCERTAINTIES ...................................................................................................... 60 14.0 COMPARISON WITH SAFETY CRITERIA AND CONCLUSIONS ........................... 60 15.0 ASPECTS REQUIRING CLARIFICATION AND RECOMMENDATION ................... 61 16.0 APPENDIX A: HOTSPOT OUTPUT FOR ACCIDENT SCENARIO 1 ....................... 62 17.0 APPENDIX B: HOTSPOT OUTPUT FOR ACCIDENT SCENARIO 2 ....................... 65 18.0 APPENDIX C: NATIONAL INVENTORY (CNRP) ..................................................... 67 19.0 APPENDIX D: CNSTN INVENTORY ........................................................................ 69 20.0 APPENDIX E: SAFRAN ASSESSMENT ................................................................... 76 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. 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No.: NLM-REP-14/197 Rev 2 Page No.: Page 6 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA List of Tables Table Table Table Table Table Table Table Table Table Table Table Table Table Table Table Table Table Table 1: References ................................................................................................................................ 8 2: Assumptions and justifications for quantitative deterministic assessment ...................................... 38 3: Basic Engineering Analyses ....................................................................................................... 40 4: Collection of DSRS at Interim Stores .......................................................................................... 43 5: Transport of DSRS ................................................................................................................... 43 6: Receipt of DSRS at CNSTN ........................................................................................................ 44 7: Temporary Storage of Cat 3 Sources and general activities in the CSF .......................................... 44 8: Conditioning Campaign 1 .......................................................................................................... 44 9: Conditioning Campaign 2 .......................................................................................................... 45 10: Transfer of Conditioned Waste Packages to the Waste Store ...................................................... 46 11: Worker Dose Summary ........................................................................................................... 46 12: Accident scenario 1 ................................................................................................................ 48 13: Accident scenario 2 ................................................................................................................ 49 14: Optimization of Protection: Assessment.................................................................................... 50 15: Quantitative Assessment: Current and Future Waste Management Practices................................ 53 16: Quantitative Assessment: Integrated Management System ........................................................ 54 17: Provisional Quantitative Assessment: Safety Case Uncertainties ................................................. 55 18: Aspects Requiring Clarification/Recommendations ..................................................................... 61 List of Figures Figure 1: Architect’s rendition of the proposed Centralized Storage Facility at CNSTN ................................. 22 Figure 2: Waste Treatment and Storage Facility Layout ............................................................................ 25 Figure 3: Proposed Radiological Area Classification of Facility ................................................................... 26 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 7 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 2.0 PURPOSE The purpose of this document is to describe the various elements of the safety case for the management of disused sealed radioactive sources in Tunisia. 3.0 SCOPE Activities regarding the management of DSRS in Tunisia are at this stage limited to storage of DSRS at user facilities. Legislation is, however, currently being developed to address various issues regarding the management of radioactive waste in Tunisia. CNSTN is busy constructing a new DSRS management facility at their site at Sidi Thabet. This facility may also in future be regarded as the national centralized DSRS management facility. For the purposes of this safety case it will be assumed that the CNSTN DSRS management facility will eventually become the national centralized facility. The scope of the safety case will include all the aspects or arguments that will ensure the safety of all management activities relating to DSRS to be performed by the National Centre of Nuclear Sciences and Technologies (CNSTN). This will include amongst others a description of the current legislation and regulations pertaining to the safe management of DSRS in Tunisia, description of the regulatory function as well as the appointed waste operator, site, facility and activity description, waste inventory, the context for the evaluation of the safety case, a safety assessment for normal and accident scenarios, a safety case compliance assessment, unresolved issues, limiting conditions, as well as management systems and procedures required to ensure compliance to set safety criteria and to sustain an acceptable level of safety. The safety assessment to be performed will be of a more generic nature due to no DSRS management activities other than storage taking place in Tunisia. The Safety Case and associated Safety Assessment for the management of DSRS in Tunisia will take the IAEA requirements with regards to predisposal management of radioactive waste [1] into consideration and will be developed and performed in accordance with the IAEA requirements and recommendations as described in [2]. The safety criteria will be taken from international safety standards and used as a basis for evaluation of safety and protection. [4] This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 8 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 4.0 REFERENCES Table 1: References 1 Number Title GSR Part 5 IAEA, Predisposal Management of Radioactive Waste, IAEA Safety Standards Series No. GSR Part 5, IAEA, Vienna (2009). 2 GSG-3 IAEA Safety Standards (2013), Safety Case and Safety Assessment for Predisposal Management of Radioactive Waste, Vienna. 3 NLM-REP-14/016 Mission Report – Safety Case Development in Tunisia 4 GSR Part 3 IAEA, Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards - 2014 5.0 ABBREVIATIONS CNRP – Tunisian National Centre of Radiation Protection CNSTN – National Centre of Nuclear Sciences and Technologies DSRS – Disused Sealed Radioactive Sources CSF – Central Storage Facility RPO – Radiation Protection Officer IAEA – International Atomic Energy Agency 6.0 6.1 DSRS MANAGEMENT DESCRIPTION IN TUNISIA Legislation and Regulations Relating to the Management of DSRS in Tunisia Tunisia currently has the following laws, Decrees and Orders pertaining to Radiation Protection; Transport of Hazardous Waste and Radiological Waste Management. They are the following: 6.1.1 Tunisian Laws - Law 81-51 of 18th June 1981 (JORT N°42 Tunis 1981: 471-472) related to the protection against ionising radiation; - Law 81-100 of 31st December 1981 (JORT N°84 Tunis 1981: 30046) related to the creation, missions and attributions of National Centre of Radiation Protection (CNRP); This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 9 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA - Law 88-91 of 2nd August related to the creation of the (ANPE) National Agency for Environmental Protection - Law 96-41 of 10th June 1996 (JORT N°49 Tunis 1996: 1192-1196) related to dangerous waste management materials including radioactive waste - Law 97-37 of 10th June 1997 (JORT N°45 Tunis 1997: 1020-1021) related to transport by road of dangerous materials including radioactive materials 6.1.2 Tunisian Decree’s - Decree No. 86-433 of 26th March 1986 (JORT N° 42 Tunis 1986: 492-497) on protection against ionizing radiation - Decree No. 2000-2339 of 10th October 2000 establishing the list of hazardous waste (including radioactive waste) - Decree No. 2002-2015 of 4th September 2002 laying down technical requirements for equipment and management of vehicles used to transport dangerous goods by road - Decree No. 2005-3079 of 29th November 2005 establishing the list of hazardous materials to be transported by road necessarily under the control and with the support of security units 6.1.3 Tunisian Orders - Order of Minister of Public Health (10/09/1986) about the information and particulars to accompany applications for approval radioactive sources and radiation devices - Order of Ministers of Interior and Transport (18/03/ 1999) about the model of safety record and the instructions for the transport of dangerous goods by road - Order of Minister of Transport (19/01/ 2000) fixing the danger labels and markings for the transport of dangerous goods by road - Order of Ministers of Interior and Transport (19/05/2000) determining the hazardous materials for which carriage must obtain a road map, the model of the sheet and the conditions of issue. The abovementioned laws and decrees are however outdated and is in need of being reviewed to be in line with current International Standards and Regulations. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 10 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Tunisia is in the process of developing a National Radioactive Waste Management Policy as well as a National Radioactive Waste Management Strategy. These documents are not yet finalised. An example of a draft policy and strategy has been provided to the CNRP by the IAEA. These documents still has to be studied by the Necsa team but it seems from the discussions that all the important aspects required for such documents have been included e.g. waste endpoints; provision of funds, decommissioning plan and allocation of responsibilities with regards to protection of workers, and population etc. Similarly a Radioactive Waste Management Agency will be constituted under the new Nuclear Law. This entity will however be a separate agency from the CNSTN. Orphan sources are addressed in the new Nuclear Draft law; the Tunisian Government will still however be ultimately be responsible for orphan sources. CNSTN is in the process of establishing a new facility for the management of DSRS at their Sidi Thabet site. This facility, although established for the CNSTN inventory, has the capacity to feature also as a national centralised facility. For a CSF to be established a mandate from government will have to be obtained. Should the CNSTN facility be decided on as the national CSF then CNSTN will have to submit a complete safety case for the facility. This safety case could, with finalization suit the purpose. 6.2 Regulatory Body Currently CNRP is fulfilling the role as the Regulator. The new draft Nuclear law does not make provision for the creation of a National Authority; i.e. a National Regulator. The aforementioned is however stipulated in a governmental Decree. The new regulatory authority will fall under the mandate of the President of the Government. The Constitution will prescribe which competencies will be necessary for the Regulator and CSF Operator to be able to manage and implement all requirements as stipulated by Tunisian law in line with International Standards and guidelines. The national waste management policy should assign the new regulatory authority the following responsibilities in terms of radioactive waste management: - Translating the policy into the national legislation. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 11 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA - Regulate and control the use of nuclear energy and ionizing radiation. Development and maintenance of a national registry for all radiation sources and radioactive materials that in use or imported or exported or disused sources including orphan sources in any form (sealed or not sealed sources) - Enforce the implementation of the regulations on radioactive waste management and spent fuel, and other national governmental organizations, such as the MOE. Ensure the fulfilment of requirements of public safety, radiation protection, and nuclear safety and security. Granting licenses and permits for radiation institutions, nuclear facilities, and workers in the radiation and nuclear fields. Issue regulations related to the following : o The safe use of nuclear energy, o Safety and security of radiation sources, o Radiation protection, o Management of radioactive waste and spent nuclear fuel, o Transport of radioactive materials, o Extracting, mining and processing of the nuclear materials. CNRP currently performs inspections at the various end-users of radioactive sources on a routine basis. These inspections are mainly based on users of sources in the medical field. DSRS are also conditioned (without removal from the working shield) by the CNRP by being placed in a cement matrix and stored in drums at the premises of the end-user. 6.3 National Safety Criteria The various regulations pertaining to the safety criteria in Tunisia are still in draft form and were not available at the time of the development of this safety case. It was, however, confirmed that Tunisia is following the international guidelines in this regard as described in [4]. These criteria are as follows: 6.3.1 Protection of Workers (Planned Exposure Situations) For occupational exposure of workers over the age of 18 years, the dose limits are: This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 12 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA a) An effective dose of 20 mSv per year averaged over five consecutive years (100 mSv in 5 years) and of 50 mSv in any single year; b) An equivalent dose to the lens of the eye of 20 mSv per year averaged over five consecutive years (100 mSv in 5 years) and of 50 mSv in any single year; c) An equivalent dose to the extremities (hands and feet) or to the skin of 500 mSv in a year. Additional restrictions apply to occupational exposure for a female worker who has notified pregnancy or is breast-feeding. Notification of the employer by a female worker if she suspects that she is pregnant or if she is breast-feeding shall not be considered a reason to exclude the female worker from work. The employer of a female worker, who has been notified of her suspected pregnancy or that she is breast-feeding, shall adapt the working conditions in respect of occupational exposure so as to ensure that the embryo or foetus or the breastfed infant is afforded the same broad level of protection as is required for members of the public. For occupational exposure of apprentices of 16 to 18 years of age who are being trained for employment involving radiation and for exposure of students of age 16 to 18 who use sources in the course of their studies, the dose limits are: a) An effective dose of 6 mSv in a year; b) An equivalent dose to the lens of the eye of 20 mSv in a year; c) 6.3.2 An equivalent dose to the extremities (hands and feet) or to the skin of150 mSv in a year. Protection of Public For public exposure, the dose limits are: a. An effective dose of 1 mSv in a year; b. In special circumstances, a higher value of effective dose in a single year could apply, provided that the average effective dose over five consecutive years does not exceed 1 mSv per year; c. An equivalent dose to the lens of the eye of 15 mSv in a year; d. An equivalent dose to the skin of 50 mSv in a year. 6.4 Waste Operator The current situation in Tunisia is that DSRS is stored at the facilities of the end users. This is a requirement written into current legislation. Most end of life sources used in the Medical This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 13 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA institutions (Category 1 DSRS) is however returned to the supplier. All users of Sealed Radioactive Sources are authorized by the CNRP. Although the legislation on the management of radioactive waste is in the process of development, it is envisaged at this stage that the responsibility for the management of DSRS on a national level will in future lie with CNSTN. CNSTN is currently also constructing a new DSRS management facility where the following DSRS management activities will take place:. 7.0 7.1 - Collection and transportation of DSRS form user facilities to the proposed CSF - Receiving of the DSRS at the CSF - Temporary storage of DSRS - Conditioning of DSRS - Pre-disposal storage of DSRS GENERIC ASSESSMENT CONTEXT Purpose of the Safety Case A safety case is a living document or set of documents that should be developed already during the design stages of a facility or the planning stages of an activity. This will then form the basis for regulatory decisions as well as operational decisions. In the case of Tunisia DSRS management activities are currently limited mainly to storage of DSRS in their working shields (some placed in their working shields in a cement matrix) at the user facilities. A DSRS management facility at CNSTN is in the final stages of construction and administrative activities relating to the management of DSRS are already taking place. The purpose of the assessment will therefore be mainly to perform a prospective assessment of the expected centralized DSRS management activities with the view of proposing additional measures to enhance the safety and security of the facility and the DSRS management activities. The following specific aspects will be addressed in this safety case: i) Demonstration of the safety of the proposed CNSTN Waste Management Facility This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 14 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA ii) Demonstration of the safety of various proposed radioactive waste management activities that will be performed by CNSTN. These activities include collection at user’s facilities, transport of DSRS to the CNSTN Waste Management facility, receiving and characterization of the DSRS, temporary storage and conditioning and longer term storage. iii) Optimization of the respective waste management activities described above. iv) Management systems implemented in support and to ensure the safety of the respective waste management activities described above. v) Definition of Limits, Controls and Conditions that will be applicable to the respective activities described above. vi) Input to and further development of existing monitoring and programmes and activity procedures. 7.2 Scope of the Safety Case The scope of the safety case for Tunisia is limited due to existing lifecycle stage of the facilities i.e. already constructed facility that is not yet operational and will therefore be focused on the as build facility and the future operational aspects of the facility which are defined as the: Collection and transport of DSRS to the proposed CSF at CNSTN; Receiving, identification, characterization and handling of DSRS when it arrives at the centralized facility at CNSTN; Temporary storage of the DSRS at the centralized facility at CNSTN; Conditioning of the DSRS for long term storage. Handling and placement into final storage. This version of the safety case will therefore not address the following: The development of waste management options and strategies and its scientific and technical bases. The development of facility designs. The siting including the site characteristics details and evaluation of possible sites. The construction and commissioning of such facilities. Decommissioning or decommissioning planning of facilities (Should be addressed in follow-up revisions). This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 15 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 7.3 Demonstration of Safety Taking cognisance of the scope of the safety case as defined in 7.2 above and the application of the graded approach as defined in 7.4 the safety of the new waste management facility will be evaluated and demonstrated by the following: 7.3.1 Basic Engineering Analysis A qualitative assessment will form the basis for the basic engineering analyses which will mainly cover the following: Basic site characteristics and credible external events have been considered in the design of the waste management facilities to ensure structural stability. Quality assurance has been considered in the design, construction, maintenance and modification the waste management facilities. The following needs to be demonstrated: - The facilities have been designed and constructed in accordance with acceptable national construction codes and standards. - Inspection and maintenance plans exist and are implemented - Formal processes are defined and implemented for the evaluation, approval and implementation of modifications (Change management) Safety and security aspects were considered in the design of the facility and the approach to demonstration of compliance refers to mainly the existence of the following features: - The characteristics of the walls allow ensuring a level of dose rate that complies with the restriction for public exposure (1 mSv/a) even for the maximum anticipated inventory and occupancy of 400h per annum i.e. 2.5µSv/h. - The lighting system will be adequate and permits the performance of operations in a safe manner. - Physical delineation of areas designed for storage and for the main waste (DSRS) management operations are isolated, this way it is ensured the appropriated segregation of materials optimizing worker’s exposure during operations. - Each delineated area has a sufficient physical space that ensures a minimal probability of accident occurrence during waste management operations and package handling. - Storage building areas were designed under the principle of labyrinth, which contributes to optimize the exposure of workers. (Waste operations are not taking place in the area where DSRS are stored). This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 16 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA - Packages with sources are stored in a manner such that packages are not in contact with the floor or interior surface of the building walls. This limits the potential of corrosion of packages/containers and allows for inspection and control operations. - Unconditioned radioactive sources are stored in storage systems ensuring normal operation and minimizing probability of accidents. Their main characteristics are: Storage capacity is greater than current and foreseen needs of management. It ensures source segregation. In this way, periodic inspection and radiological monitoring of the storage building and of the waste drums/packages is facilitated. Its structure resists the maximum load of the sources that are intended to be stored. - There is a vault with special shielding structure that minimizes worker’s exposure for the storage of sources of greater or unknown activity that could have not been conditioned. - For situations of operational occurrences and accident due to internal operational factors, the engineering systems ensuring safety are: Floor and wall finish allow easy decontamination The segregation of the different areas limits the potential dispersion of any contamination. In case of a potential surface decontamination using liquids there is a collection system inside the facility that prevents its release to the environment. The system has a retention tank that permits environmental monitoring before releasing to the environment. - The facility has its own fire detection and fire-fighting equipment. The facility design makes provision for physical security features commensurate with the anticipated security threat. Design features include the following: Robust building construction with high integrity doors and locks to the treatment and storage areas. Buildings are equipped with intrusion alarms. The buildings have vehicle access points. A separate personnel door is provided to segregate personnel from vehicle movements. No windows are provided in the storage areas so as to improve its shielding and security performances. Security fence around facility. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 17 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 7.3.2 Demonstration of the safety of various radioactive waste management activities performed by CNSTN. Quantitative and qualitative assessments will be performed to assess the impact of the waste management activities as listed in 7.2 above. Results will be assessed in terms of the safety criteria. The following specific assessments will be performed: For normal operation; quantitative deterministic assessment of worker dose due to the range of activities by various occupational groups of CNSTN; For anticipated operational occurrences: quantitative deterministic assessment of worker and public dose as applicable; All other credible occurrences; a quantitative and qualitative assessment of the impact of other occurrences and the listing of specific preventative and mitigating measures. (At the time of the country visit to Tunisia no management activities were yet taking place. Real time measurements could therefore not be obtained for the activities. Radiological assessment will be based using a conservative approach combined with a realistic approach where possible. The assessment will rely on typical exposure data collected during similar type exercises elsewhere taking cognizance of the activities and types of DSRS mostly handled.) 7.3.3 The results from the quantitative and qualitative assessment as defined in 7.3.2 above will also be compared to the proposed target and objectives set for the optimization of protection. 7.3.4 A qualitative assessment of the non-radiological hazards of the facilities and the listing of specific control measures will be performed. 7.3.5 A qualitative assessment of the implemented waste management practice; – The approach to waste management will be regarded as a contributing factor to safety. 7.3.6 A qualitative assessment of the availability, level of implementation of an integrated management system to ensure a sustained level of safety during the operational phase of the facilities will be undertaken. This assessment will focus on RP, work procedures, QA aspects and processes for the management of limits and conditions. 7.3.7 Uncertainties inherent to the assumptions made in the quantitative assessments or any other uncertainties identified during the safety assessment will be evaluated to determine its impact on This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 18 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA safety. Uncertainties with a significant impact on safety will be listed with recommendation for its management. 7.4 Graded Approach A graded approach is applied for defining the extent and depth of this safety case. The main factors for justification of a limited approach towards the safety assessment are the following: The simplicity of the activities involving the management of DSRS. Most of the activities involving DSRS entail handling of the DSRS inside robust working shields which limits external exposure potential. • The radiological hazard when undertaking the various management activities involving DSRS (especially Cat 3-5) can be regarded as low. This once again, as described above, is due to the simplicity of the activities handling only DSRS inside their working shields. The only time that bare DSRS will be handled during normal operational conditions in any DSRS management facility is during source conditioning operations. In such instances the risk is reduced by performing the work in accordance with specific works procedures and under work permit systems where there is permanent radiation protection controls in place. Inherent high level of passive safety associated with the DSRS management operations and the limited reliance on active protection systems. 7.5 Safety Strategy The strategy for safety refers to the approach that was taken in the facility design and all the respective DSRS management activities to comply with the regulatory requirements and to ensure that good engineering practice has been adopted and that safety and protection are optimized. The safety case for Tunisia will take into account the following safety strategies during the management of DSRS: - Defense in Depth – In this instance care is taken to ensure that multiple safety layers are available. This principle is followed for all the respective management processes for instance: o To ensure containment of DSRS during transport from user facilities all over Tunisia. The DSRS inside their working shields will be packaged inside a specially manufactured secondary container. This box will form a secondary barrier should the DSRS for some or other reason gets separated from its working shield during transport. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 19 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA o After receiving of a unit containing a DSRS at the CNSTN CSF the RPO will first take measurements to ensure that the DSRS is still within the working shield. o During conditioning the RPO will continuously monitor and ensure that no exposure levels exceed the criteria set for the respective activity. - Shielding – Shielding is used to ensure that doses to workers and also the public, as low as possible. This is applicable to all activities including storage. One example is that the transport containers mentioned above under defense in depth are also lined with lead in order to keep the exposures to members of the public during transport at the lowest possible levels. Shielding is selected based on the type of DSRS and the sources activity. - Approaches during the management of DSRS in Tunisia. The proposed national waste management strategy will highlight the principles of waste minimization and avoidance, reuse or re-processing of waste, safe and secure storage and conditioning and final disposal of waste. These principles will be followed by CNSTN for the management of DSRS: o Secondary radioactive waste is only expected when a leaking source is found or during accident scenarios when a source is damaged. The generation of secondary waste during such an incident will be minimized by isolating the source in a secondary containment to prevent further contamination. o The draft national policy encourages a “return to supplier” principle when procuring sources. This principle will be followed as far as practical achievable in order to avoid radioactive waste. o Storage of DSRS will only take place inside proper containment such as the original working shields or another type of suitable containment. For storage of the DSRS in the CSF personnel shall take into account the ambient dose rates measured in the respective storage rooms. The DSRS will be stored in a way that will provide the lowest possible dose rate in the areas that personnel normally occupy when they enter the respective storage rooms. o Recycling of sources stored at the CNSTN CSF will be encouraged and applied by CNSTN. 8.0 FACILITY AND PROCESS DESCRIPTION A new facility for the management of radioactive waste is currently under construction at the “Centre National des Sciences et Technologies Nucleaires” (CNSTN) in Sidi Thabet, Tunisia. This facility has been constructed for the management of the national radioactive waste inventory. It was decided, however, after discussions with the regulatory authority, that the store could not currently This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 20 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA be used as a national waste management facility due to the absence of applicable legislation and regulations to this extent. 8.1 8.1.1 Site Conditions General description of the site The land where the Facility is constructed, is on the CNSTN site which is located in Sidi Thabet, which is located north of Tunis and about 20 km from the Tunis city centre. About 8km from the Mediterranean sea. There are various building and laboratories on the site which is about 5km2. It is located in a semi farming area. The site is located against a slight ridge and the CSF is located highest against this ridge. Thus any water flow from the facility will be into the site. Elaborate and correct this data 8.1.2 Demography The demographic data is based on census studies performed during xxxx. The main demographical findings are the following: Total population of Sidi Thabet as per 2004 is 8909 Distribution of population in a radius 20 km around the site: 0 - 1 Km : X Inhabitants 1 - 2 km : X Inhabitants 2 – 5 km : X Inhabitants 5 – 20 km : X Inhabitants. Population growth: to be included 8.1.3 Meteorology • Local meteorological conditions: To be included • Wind conditions: To be included. • Temperatures: To be included • Humidity: To be included • Cloud cover: to be included • Evaporation: to be included • Precipitation: to be included This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 21 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 8.1.4 Site Geology and Geohydrology Include relevant Geological and hydrogeological information on the site, that was considered for the design and construction of the waste management facility. 8.1.5 Site Seismology Include info about seismology of the site. Specify the actual reference seismic event that was used in the design and construction of the waste management facility. 8.1.6 Aircraft Crash Probability To be included here 8.2 Facility Description The purpose of the storage facility will at this stage be limited to the management and storage of radioactive waste generated at the CNSTN facilities only. The radioactive waste inventory of CNSTN consists mainly of disused sealed radioactive sources (DSRS). The current situation in Tunisia is that DSRS is stored at the facilities of the users. This is a current strategy by CNRP in awaiting the national policy and strategy on Radioactive Waste management. Most end of life sources used in the Medical institutions (Cat 1 and 2 DSRS) is however returned to the supplier. All users of Sealed Radioactive Sources are authorized by the CNRP. All DSRS collected in Tunisia should however ultimately be brought to the proposed CSF for storage and further management. The facility at CNSTN can be described as follows: The facility consists of a single building with an administrative block with two levels containing the building main entrance, various offices, laboratories, parking bay for the mobile laboratory, ablution facilities and finally the clean entrance sides to change rooms (see picture in Figure 3). The change rooms lead into the main waste management facility. The radioactive waste management facility consists of a concrete structure of which the main operational areas consist of the following: - Receiving and treatment hall (Main Hall). The surface area of this hall is about 160 m2 and a height of 7.1 m. The external walls of the facility are constructed of concrete (0.40 m thick up to a height of 5 m and 0.2 m thick from there). The roof is constructed from a combination of hollow This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 22 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA blocks and concrete (0.19 m hollow blocks and 8 cm concrete). Allowance has been made for windows at a level about 0.5 m from the roof. - Storage room. This room has a surface area of about 46 m2 with concrete walls and is about 3.1 m high. The external walls of the storage facility are 0.27 m thick. The internal wall bordering the measuring laboratory is also 0.27 m thick while the internal wall bordering the main hall is 0.20 m thick. The roof of this storage area is of the same design as the roof the main hall. - Laboratory (analysis, measuring etc.). This room, adjacent to the storage room and accessed from the main hall, has concrete walls and a surface area of about 30 m2. - Change House and amenities and access to main hall and storage facility. An architect’s rendition of the proposed facility currently under construction at CNSTN of the CSF is presented below as Figure 1. Figure 1: Architect’s rendition of the proposed Centralized Storage Facility at CNSTN 8.2.1 Facility Design and Construction. Basic information regarding design considerations, applied design and construction codes and standards needs to be obtained to justify the new facility design building integrity and stability. Design and construction documentation e.g. facility layout, civil design, electrical design, etc, design review and construction reports as well as certificates of conformance should be referenced here. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 23 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Safety related assumptions on which the design of the facilities has been based also need to be obtained and listed here. (e.g. The building structure and associated civil infrastructure has been designed to cope with external environmental events. The design basis for these external environmental events will consider events with a return frequency of 1 in 100 years using data for the local area and will provide conservative design margins) It should be confirmed that the seismic hazard of the region has been taken into account in the design of the facility. Basic information regarding the ground accelerations level that the facilities would be able to withstand and its justification should be provided. -to be confirmed. 8.2.2 Main Safety and Security Related Design Features 8.2.2.1 Building structure The foundations, columns, walls and roof have been designed to support all super imposed structural loads as well as all applicable dead loads; - Provide reference to design documentation covering loads used as design inputs The floor slab is able to support the concentrated point loads of the waste containers 5 t per m2, and an impact load of resulting from accidental dropping of waste container of 5 t from a height of 2 m, as well as live loads of vehicles/equipment used to load the packages; - Provide reference to design documentation covering loads used as design inputs The slab will be sufficiently thick around the building perimeter to support the walls and locally around all internal stanchions; - Provide reference to design documentation covering loads used as design inputs Rain water will be prevented from entering the buildings by surface contouring and drainage channels around the buildings. – Provide reference to design documentation Resistance to water penetration from the ground will be provided by a polyethylene damp proof membrane to the underside of the slab; - Provide reference to design documentation The interior construction of the building will be such that the risk of any liquids being released to the environment is minimized; - Provide reference to design documentation The buildings will be provided with an internal floor drain system to direct any internal liquid traces generated to a sump pit of capacity at least 1m3. The floor will be sloped to facilitate movement of liquid away from the storage areas toward the floor drains. There will be provision for inspection of the sump and sampling of accumulated liquid. - Provide reference to design documentation This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 24 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA The floor slab will have a steel floated finish with an epoxy paint coating to provide a hard wearing and decontaminatable surface; - Provide reference to design documentation Where ducts, pipes or cables that pass through walls or the floor, suitable means to accommodate expansion and provide fire resistance will be provided and they will be such that the structural and fire integrity of the building is not impaired. Water proofing will be applied at the entry point to a building - Provide reference to design documentation 8.2.2.2 Shielding The design and construction ensure the required shielding is provided for (see dose assessment assumptions) and that no major cracks or shine paths are present in the as constructed building. To be confirmed. Individual packages will be shielded by other packages, internal building structures or by concrete blocks. The external wall thickness of the storage area has been increased to 270mm to provide optimum shielding for the stored DSRS. The radiation outside the facility will depend on various factors, which include: external wall thickness and density, external radiation on packages, nuclides, package design, total facility inventory and storage configuration. Due to the number of factors, it is not possible to determine the maximum nuclide and activity inventory of the facility which will ensure that the radiation outside the facility will be acceptable for possible public exposure. For this reason routine RPO surveys outside the facility are required. These then needs to confirm that radiation levels remains less than 10 x natural background levels (or any limit prescribed by the regulator). 8.2.2.3 Access and Physical Security Physical security will be provided primarily by a number of passive physical barriers including a site perimeter fence, a site security access point, strong building construction, high integrity doors and locks to the treatment and storage areas. Buildings will be equipped with intrusion alarms. –to be confirmed The building has one vehicle access point. A separate personnel door will also be provided to segregate personnel from vehicle movements. In the case of the waste treatment facility and in the interest of security only the personnel door can be opened from outside. -confirmed Allowance has been made for windows at a level about 0.5 m from the roof for the purposes of providing additional natural lighting and will not impact on the shielding and security performances. These windows cannot open. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 25 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 8.2.2.4 Waste Treatment and Storage Facility Layout The layout of the waste treatment facility is illustrated in Figure 2 below; Deconta mination bay (with drain to tank) Figure 2: Waste Treatment and Storage Facility Layout The following activities will take place in the Receiving and Treatment Hall: - Receiving of DSRS - Characterisation and conditioning of DSRS - Decontamination in Decontamination Bay Areas in which DSRS are present are subject to radiation protection control measures. Interior walls will separate the storage area from the receiving and conditioning area and provide radiation shielding. Access to the storage area will be via a labyrinth type arrangement (wall in front of the storage room door) to provide easy access and at the same time reduce radiation shine. The proposed classification of the radiologically controlled areas of the facility is illustrated in Figure 3 below. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 26 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Controlled area Controlled area Controlled area Decontamination bay: Controlled area for both contamination and radiation during conditioning campaigns and decontamination work All four areas: change house, laboratory, storage and receiving area: always controlled area for radiation Figure 3: Proposed Radiological Area Classification of Facility All the operational areas will be controlled areas. Due to the nature of DSRS, there is very small change of leaking sources and possible spread of contamination. However during the possible decontamination work and conditioning of the sources there is a possibility of contamination, for this reason access to the controlled area will at that stage be both controlled for radiation and contamination. Thus typically personnel entering the area during conditioning of sources will require wearing protective clothing (overall), overshoes and gloves. On exit of the area, each person will have to be checked for contamination in the change room. During these activities the vehicle entrance to the receiving area will remain closed and no vehicles would be allowed to enter the facility. All personnel access will the through the change rooms. the facility RP programme. This will need to be prescribed in This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 27 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Drums/packages will be placed in a manner such that packages do not contact the interior surface of the building walls and so as to allow access to visually inspect packages and wall surfaces for degradation and to allow for easy retrieval; 8.2.2.5 Fire protection Fire protection is provided by the utilisation of construction materials that are not flammable and by forbidding any flammable materials to be introduced into the store. Fire detection and fire fighting equipment will be installed. Such equipment will be tested and maintained. High quality electrical equipment complying with national quality standards is installed in both the buildings. The site will be maintained clear of vegetation and combustible materials will not be stored on the site. Fire detection equipment will be installed, fighting equipment will be provided and strict compliance will be maintained with national and local fire regulations. 8.2.2.6 Ventilation The waste management facility building will be provided with natural ventilation; outlets will be located high on the building walls and covered with grids to prevent the access of animals, birds and insects. No ventilation is provided for in the storage room. A local extraction hood will be installed at the conditioning area. The extracted air will be filtrated through a High-Efficiency Particulate Filter (HEPA) to prevent the potential release of radioactive materials. The extracted air will be released outside the facility into the atmosphere. These filters have a high efficiency to capture any possible contamination which could be released when a damaged or leaking source is handled and conditioned. 8.2.2.7 Electrical power and Lighting Electrical power is provided for lighting, small power tools and security detection/warning equipment. All installations and equipment are of high quality and will comply with national standards. Good levels of lighting is provided throughout the treatment and storage facilities and quality, long life components are used to reduce maintenance needs. (Provide a reference to an installation report or Electrical Certification of Compliance) 8.2.2.8 Mechanical handling equipment Readily available and good quality manually operated mechanical handling equipment need to be available once the facility becomes operational. Such equipment is subject to national regulation/requirements as applicable to statutory equipment (e.g. maintenance, inspection and load test records) and is used/operated by trained/licensed operators. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 28 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 8.3 Proposed Facility Operation Due to the fact that the proposed Central DSRS Management Facility is currently still under construction at CNSTN, the Facility Operations that will take place in the future will rely on typical data collected during similar type operations elsewhere taking cognizance of the activities and types of DSRS mostly handled. Proposed operational activities within the waste management facility involve reception, treatment, conditioning and emplacement of packages in the store, inspection and characterisation of DSRS, equipment and the stored packages and maintenance of the building and equipment. At this stage however no neutron sources will be conditioned. On review of the current Tunisian inventory there are not many neutron sources, and for that reason the possible dose impact of these will not be included in the safety case. It is possible that some minor repairs may be carried out from time to time to the source housings, packaging or containers. The facility design is such as to make these operations simple and easy to undertake in the least time possible. Written operational procedures will be drawn up to ensure the activities are carried out safely and in the least time reasonably possible and to optimize safety and protection and to ensure that no individual dose constraints or limits are exceeded. Operational radiation protection, maintenance and inspection programmes will be formally documented and approved, an incident reporting system and emergency plans will be drawn up and approved. These programmes will be drafted and implemented based on and justified by this safety case. Reference the applicable procedures. Records will be maintained of all operational activities, packages and equipment will be clearly marked and labeled and an inventory maintained of all equipment, DSRS and waste placed in the store. 8.3.1 Proposed Waste Management Facility Operation DSRS will be collected from the current owners by the Central Waste Management Facility personnel. These will be checked, loaded and then transported in accordance with the applicable IAEA transports requirements (IAEA SSR-6: Regulations for the safe transport of radioactive material) This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 29 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA The transported DSRS will be received at the Central Waste Management Facility at CNSTN. The sources will be surveyed, off loaded, inspected and segregated. Approximately 10 consignments with a total of 20 sources will be received annually. The DSRS will be transferred to the storage room in the Central Waste Management Facility at CNSTN. The received units will be placed in the receiving hall for temporary storage. Conditioning of the standard Category 3 sources will be done on a batch basis. During this operation the sources in their working shields will be removed from their storage location and placed on a working area equipped with a lead shield (this shield allows the operator to remove a source from the unit, while his body is being shielded). Standard Category 3 sources are those that are typically in a good condition, e.g. not corroded, source shutter and positioning mechanism still in a good working condition. Thus to remove the source will be quite easy and quick. The sources will be removed from their working shields, inspected, source and unit information recorded, consolidated and seal welded in a stainless steel capsule, capsule/s placed into a lead shield and lead shield placed into a retrievable concrete shielded storage container. The storage container is also closed and prepared for long term storage. It is assumed that 30 sources are conditioned in a year. Due to the radiation risk during the handling of unshielded sources, this conditioning operation is done under the supervision and oversight of the facility RPO. Non-Standard Category 3 sources will be collected from their storage location in their working shields and placed on a working area without shielding. These non-standard category sources units and equipment are typically those that are difficulty to open or remove the source. Due to the difficulty with the equipment (source still shielded inside the equipment) the equipment cannot be handled behind a shielded work area. However as soon as the source can be removed from the equipment, the source is directly moved behind the shielded work area, where the source can be identified, characterised and transferred into the capsule. The further steps followed are the same as done with standard Category 3 sources, described above. Once the lead shield with the encapsulated DSRS has reached its filling capacity, the lead shield in placed in a retrievable concrete shielded storage container. The concrete container is closed with steel bars to prevent easy accessibility to the lead shield, where after the drum is closed with a lid and clamp. The sources inside the shielded container are retrievable. The final waste package is thereafter transferred to an interim storage area where the waste package it left to cure. Two such campaigns are conducted per annum. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 30 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA The facility is visited by the facility operators for approximately 8 hours per month for general cleaning, inspection and maintenance purposes. Final storage waste packages are transferred to the waste storage facility and emplaced in the storage room. Two such campaigns are conducted per annum. The waste storage room is inspected and monitored on a monthly basis The facility is visited by the facility RPO for approximately 4 hours per month for the routine radiological inspection and surveillance purposes. 8.3.2 Operational Radiation Protection The waste treatment and storage facilities are designated and operated as a radiological controlled areas and people working in the facility are designated as occupationally exposed persons with the necessary training, dosimetry and medical control. A radiation protection programme will be implemented and will cover routine monitoring of the facility and its environment, monitoring of specific operations such as treatment and emplacement activities and any special monitoring that may be required from time to time. The programme will make provision for the monitoring of external radiation levels and surface contamination and also include the access and egress control measures applicable during the different operations. 8.3.3 Management System The establishment and implementation of an integrated management system is important for the proper management of DSRS. A management system for the processing, handling and storage of Radioactive Waste compliant with international safety standards needs to be demonstrated by CNSTN. Written operational procedures will be drawn up to ensure the activities are carried out safely and in the least time reasonably possible to optimize safety and protection and to ensure that no individual dose constraints or limits are exceeded. A formally documented and approved management system that integrates radiation protection QA, operational, maintenance and inspection programmes to ensure protection and safety are optimized and that no personal dose limits or constraints are exceeded needs to be implemented. The management system will inter alia include an incident reporting system, emergency plans and document and record management. The integrated management system must be continuously updated and will reflect the recommendations from this safety case. Refer here to system manuals and procedures. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 31 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Records must be maintained of all operational activities, packages and equipment must be clearly marked and labelled and an inventory must be maintained of all equipment and waste placed in the store. 8.4 DSRS Inventory CNSTN maintains a DSRS inventory of the sources used at their facilities by using RAIS 3.0. See Appendix D. Similarly CNRP maintains a national waste inventory on RAIS 3.0 but are in the process of moving inventory to RAIS WEB. A copy of the current inventory is included as Appendix C. CNRP are however in the process of updating the National Inventory. This safety case needs to be updated with the latest national inventory once it becomes available. CNRP has indicated that there currently are ± 100 DSRS (inside their working shields) that has been conditioned and placed in a cement matrix and is currently controlled by the CNRP and stored at the respective user facilities. Conditioned Ra-226 sources from former medical activities are currently stored at a local storage facility which belongs to the ministry of health and controlled by CNRP. Low Activity Check sources are kept at the premises of the CNRP laboratories for training purposes. 9.0 SAFETY ASSESSMENT 9.1 Safety Assessment Context The purpose and philosophy for the safety assessment have been defined in section 7 of this report for the scope of this safety case as defined in 7.1 specifically. Section 7.0 covers some information related to the strategy for safety assessment which will be expanded in this section. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 32 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 9.1.1 Strategy for Safety Assessment 9.1.1.1 Basic Engineering Analyses The list of the required engineering aspects and design features as listed in section 7.3.1 will be used as a checklist to qualitatively assess and comment on the compliance of the waste management facilities to the specific requirements. 9.1.1.2 Demonstration of the safety of the radioactive waste management activities performed by CNSTN. • For normal operation; quantitative deterministic assessment of worker dose due to the range of activities by various occupational groups of CNSTN; the breakdown of normal operational activities are the following: - Collection of DSRS at User facilities: Two Loaders from CNSTN inspects and load consignments into a vehicle that is dedicated for transportation of sealed sources. - Collected DSRS are transported in a dedicated vehicle by 2 drivers from Users and interim storage locations to the Central Waste Management facility at Sidi Thabet. - The transported DSRS are received at the Central Waste Management Facility at CNSTN. The sources are surveyed, off loaded, inspected and segregated. Approximately 10 consignments with a total of 20 sources are received annually. - The DSRS are transferred to the storage room in the Central Waste Management Facility at CNSTN. - Standard Category 3 sources in their working shields are removed from their storage location and placed on a working area equipped with a lead shield. The sources are removed from their working shields inspected, characterised, source and unit information recorded, consolidated and seal welded in a stainless steel capsule, capsule/s placed into a lead shield and lead shield placed into a retrievable concrete shielded storage container. The storage container is also closed and prepared for final storage. 30 sources are conditioned per year. - Non Standard Category 3 sources are collected from their storage location in their working shields and placed on a working area without shielding. The sources are removed from their working shields inspected, recorded and placed into a shielded storage container. One source is dismantled per campaign and 3 campaigns are conducted annually. - Once the lead shield with the encapsulated DSRS has reached its filling capacity, the lead shield is placed in a retrievable concrete shielded storage container. The container is closed with steel bars and closed with a lid and clamp. The waste package is thereafter This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 33 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA transferred to an interim waiting area inside the main hall of the waste management facility where the waste package is left to cure. Two such campaigns are foreseen to be conducted per annum. - The waste operational areas of the central waste management facility is visited by the facility operators for approximately 8 hours per month for general cleaning, inspection and maintenance purposes. - Cured waste packages are transferred to the in the storage room. Two such campaigns are conducted per annum. - The waste storage room is inspected and monitored by the facility RPO on a monthly basis for a total of 4 hours. • For anticipated operational occurrences: quantitative deterministic assessment of worker and public dose as applicable. Specific credible and enveloping scenarios will be developed and doses to workers and public as applicable will be calculated with the use of simple models and the use of conservative assumptions. • All other credible occurrences; Qualitative assessment of the impact of other occurrences and the listing of specific preventative and mitigating measures. Other design basis and beyond design basis events will be considered and enveloping scenarios will be developed. The anticipated consequences associated with such events will be listed with comments/recommendation for further analyses and/or proposed preventative and mitigating measures. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 34 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 9.1.1.3 The results from the quantitative and qualitative assessment as defined in 9.1.1.2 above will also be compared to the proposed target and objectives set for the optimization of protection. No specific optimization comments and recommendations will be made in the case of doses below 1 mSv/a. 9.1.1.4 A qualitative assessment of the non-radiological hazards of the facilities and the listing of specific control measures will be performed. Non-radiological hazards will be listed and categorized in terms of its hazard potential. Comments and recommendation will be made per hazard as applicable. 9.1.1.5 A qualitative assessment of the implemented waste management practice; – The approach to waste management with regards to the following will regarded as contributing to the inherent level of safety: Clearly defined responsibilities for waste management. Implementation of the principles of waste minimization and avoidance, namely, re-use or reprocessing of waste, return to supplier, safe and secure storage and conditioning and final disposal of waste. Hazards and the generation of secondary waste, associated with all waste management operations (routine and ad hoc) are known, monitored, projected and managed by due management processes. Interdependencies between the various steps of waste management are known and managed. Waste acceptance criteria are defined, waste management activities and the outputs of such activities are aligned with set waste acceptance criteria. Interim storage of DSRS will only take place inside proper containment such as the original working shields or another type of suitable containment. Conditioned DSRS will be stored in a dedicated storage area with passive safety features and adequate access control. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 35 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 9.1.1.6 A qualitative assessment of the availability, level of implementation of an integrated management system to ensure a sustained level of safety during the operational phase of the facilities will be conducted. This assessment will focus on RP, work procedures, QA aspects (mainly recordkeeping and change management) and processes for the management of limits and conditions. 9.1.1.7 Uncertainties inherent to the assumptions made in the quantitative assessments or any other uncertainties identified during the safety assessment will be evaluated to determine its impact on safety. Uncertainties with a significant impact on safety will be listed with recommendation for its management. 9.2 Safety Assessment Endpoints The following quantitative assessment endpoints will be applicable: - Radiation dose to workers performing the various normal DSRS management activities at CNSTN radiation doses to worker and the public as applicable due to anticipated operational occurrences. It should be noted that it is expected and assumed that the same CNSTN personnel will be performing all the respective DSRS management activities at CNSTN. Doses received during the various activities are therefore accumulated for these workers. Doses will be evaluated against the safety criteria as listed in section 6.4 and will also be compared with latest IAEA recommended annual dose limits for occupationally exposed persons as described in [4]. - 9.3 9.3.1 The assessments will cover activities taking place over a 1 year period. Development of Scenarios Normal Operations The normal operations scenarios for which worker doses are quantified are listed in 9.1.1.2 above. A separate spread sheet is developed for each activity and all relevant assumptions are listed below each spreadsheet. (See Section 10.0.) 9.3.2 Accident Scenarios 9.3.2.1 Anticipated Operational Occurrence Scenarios The consequence of following postulated initiating events will be evaluated: This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 36 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA - Operational Occurrence 1 The CNSTN transport vehicle carrying three working shields with DSRS during the transport of these units from the end user to the CNSTN waste treatment facility is involved in an accident. The vehicle complies with the applicable requirements of the IAEA transport regulations, thus having the applicable signs on the truck and Tremcard available inside the vehicle. The vehicle capsizes, the driver/s cannot take emergency response action due to injury, and the working shields with DSRS are flung from the vehicle and end up next to the road. The working shields were all packaged inside one secondary container which could not withstand the impact which led to the three units being separated from each other. The working shields are, however, still intact with the DSRS inside and no loss of containment takes place. The tree units contained two Co-60 sources, each with an activity of 25 mCi and one Cs-137 source with an activity of 50 mCi. First responders and other members of the public arrive at the scene of the accident and spent one hour in close proximity (1 m) from the sources, before other CNSTN arrive on the scene and ensure the public is kept at a safe distance from the vehicle. The sources are recovered and surveyed by CNSTN RPOs and operators (30 min in close proximity) who then continue with loading and transportation of the sources. - Operational Occurrence 2 The operator left a bare Cat 3 Co-60 source on the shielded workbench during the conditioning campaign and removal of the source from its working shield in the waste treatment facility at CNSTN. The operator did not wear his EPD and was under the impression that the source was placed inside the shielded waste storage container and continued to work on another working shield to remove the source. No alarm was made and the RPO invigilation was interrupted. When the RPO returned after 45 minutes the elevated dose rate in the area was detected. The RPO immediately evacuated the working area after which the misplaced source was detected and placed inside the shielded container. - Operational Occurrence 3 During the conditioning campaign of non-standard Cat 3 sources, the operators dismantled an unknown/non-standard source without the aid of the shielded work bench. After the primary shield has been removed the dose rate in the area increased to above expected levels. Since the source was unknown to the operators they did not know how to remove the source. The operators panicked, did not evacuate the area and continued to try to remove the source and spend 15 minutes in close proximity of the source before they managed to remove the source and place it in the shielded storage container. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 37 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 9.3.2.2 Other Accident Scenarios The following other accident scenarios will be considered: - Accident Scenario 1 The electrical wiring in the waste treatment facility creates a short circuit that results in a fire. The fire spreads and causes the smoke detectors to activate an alarm. Some of the working shields are being damaged by the fire before any fire-fighting personnel could arrive. A 50 mCi Cs-137 source is ruptured in the process and starts leaking. Fire-fighting personnel arrive and by using powder based fire-fighting equipment managed to quench the fire. With an assumed release fraction of 10 % (5 mCi), contamination spread by the fire into the facility while 20 % (10 mCi) of the released activity escaped from the building through the natural ventilation system and through the opened doors to the environment. Fire-fighting personnel used respirators and spend 20 min in the contaminated zones. After the fire was put out, the remaining activity settled in the areas. Workers used protective suits and respirators to cleanup the contaminated zones. - Accident Scenario 2 During transport of two 10 mCi Cs-137 sources inside their working shields the CNSTN transport vehicle is in involved in an accident and caught fire. The operators/drivers are not in a position to remove the units from the vehicle. Due to the extreme heat from burning vehicle fuel the sources are damaged to the extent that it starts leaking. The fire causes the contamination to disperse to the immediate environment. Members of the public (residence in the area close to the accident) are in close approximation of the burning vehicle and exposed to the dispersed contamination. A release fraction of 10 % (2 x 1 mCi = 2 mCi) and conservative metrological conditions are assumed. - Accident Scenario 3: A DSRS waste container which is not filled to capacity and not conditioned are collected from the receiving and treatment hall in the Waste Treatment and Storage Facility. The container contains thirty 50 mCi Cs-137 sources. During lifting of the container with the overhead crane, the container slipped and fell to the floor of the reception area of the Storage Room. On impact the container lost its lid and all the sources. The sources were in close approximation from each other. This happened close to the operator who spends 30 seconds This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 38 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA within 1 m from the sources before the area is evacuated. After emergency intervention and planning the operator spend 30 minutes at an average distance 1.5 m from the sources collecting them with tongs and placing them into a shielded container. The RPO supervised this operation at an average distance of 3 m from the sources. The container was closed and transferred back to the Storage Room. 9.4 Data Used and Assumptions Made for the Safety Assessment In order to perform the calculations for the safety assessment for the DSRS management activities in Tunisia certain measured and calculated data will be used. In some instances, however, real-time data is not available resulting in making certain assumptions. These assumptions are based on experience performing similar types of activities elsewhere in the world. The assumptions made are generally conservative. The current inventory of CNSTN (Appendix C) and the national inventory kept by the CNRP (Appendix B) were reviewed. The assumed values and justification for selection are reflected in Table 2 below. Some of these values are based on non-Tunisian experience since no actual data is available. These assumed values should be changed as soon as local data is available. Table 2: Assumptions and justifications for quantitative deterministic assessment Condition 1 Dose Rate Justification Ambient dose rate 15 µSv/h Typical ambient dose rate in a store full with DSRS in Storage room units (units packed on various shelves and racks, raks about 1.5m apart) Dose rate measured between racks and in walkways) 2 Ambient dose rate 10 µSv/h The DSRS inventory in the receiving area will typical in Receiving hall be less than in the Storage room, thus assume a lower rate than in the storage room. 3 Average contact 70 µSv/h Typical average contact dose rate on DSRS dose rate on DSRS units/equipment (as recorded on units received at units Necsa (South Africa)- and equipment Can be changed based on CNSTN experience – no dose rate results on units at CNSTN available 4 Average dose rate 5 µSv/h Typical 1m DSRS units/equipment (as recorded on units received at and Necsa (South Africa)- Can be changed based on from units equipment average dose rate 1m from DSRS CNSTN experience – no measurement result on units This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 39 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Condition Dose Rate Justification at CNSTN available 5 6 Unshielded Cat 3 12000 µSv/h No sources are handled by hand, thus always by source dose rate at tongs, assumed to be 0.5m long. 0.5 m conservative average dose rate (70% of maximum, Unshielded Cat 3 1200 µSv/h see below) of the Tunisian Cat 3 inventory. source dose rate at The inventories were reviewed and Co-60 and Cs-137 1.5 m were found as the nuclides with high energy gammas and which are in the majority. This value is Maximum current activity of Cat 3 Co-60 and Cs-137 DSRS in the CNSTN inventory is 14.8 mCi and 0.223 mCi respectively. Maximum current activity of Cat 3 Co-60 and Cs-137 DSRS in the national inventory is 0.368 Ci and 40 mCi respectively. The average activity of both inventories is significantly lower. 0.5m dose rate for max Co-60 0.368Ci is 16700 µSv/h. 1.5m dose rate for max Co-60 0.368Ci is 1800 µSv/h. 7 Whole body dose 50 µSv/h Removing sources behind 10 cm lead brick wall on the due to shielded Cat working bench. 3 source at 0.5m bricks with hands not shielded. behind 10cm lead assumptions for 5 and 6 above Person stands directly behind lead Refer also to working shield 8 9 Average dose rate 50 µSv/h Typical average dose rates on a final package (e.g. 1m final 210L metal drum lined with concrete and cavity in package containing centre for a lead shield containing several capsules. conditioned DSRS These capsules each contain several DSRS). from Average contact 1000 µSv/h dose rate on final package containing conditioned DSRS This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 40 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 10.0 SAFETY ASSESSMENT 10.1 Basic Engineering Analyses Table 3: Basic Engineering Analyses Item Requirement (Note 1). Compliance Ref 1. General: Facility Design, Construction and Maintenance 1.1 Basic site characteristics and To be confirmed credible external events have been considered in the design 1.2 Quality assurance has been No design information has considered in the design, been supplied. construction, maintenance and modification the waste management facilities: Design approval and The facilities have been designed and constructed in certificates to be supplied. accordance with acceptable national construction codes and standards. Plans to be developed or - Inspection and maintenance plans exist and are supplied. implemented To be supplied - Formal processes are defined and implemented for the evaluation, approval and implementation of modifications (Change management) 2. Safety and security aspects were considered in the design of the facility 2.1 The characteristics of the walls To be modelled or to be ensuring a level of dose rate included as a facility limits that complies with the restriction and included in the for public exposure (1 mSv/a) procedure for even for the maximum management of the anticipated inventory. facility limits and conditions. 2.2 The lighting system will be To be demonstrated by adequate and permits the facility lighting performance of operations in a measurement (lumens) to safe manner. be confirmed on an annual basis. 2.3 Physical delineation of areas . Main storage area is designed for storage and for the isolated from the waste main waste management operations areas. operations are isolated, this way - separate it is ensured the appropriated decontamination area segregation of materials within main storage optimizing worker’s exposure facility will be demarcated Comments Storage room has walls 270 mm thick to provide shielding This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 41 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Item 2.4 2.5 2.6 2.7 Requirement (Note 1). during operations Each delineated area has a sufficient physical space that ensures a minimal probability of accident occurrence during waste management operations and package handling. Storage areas were designed under the principle of labyrinth, which contributes to optimize the exposure of workers. (Stored DSRS and waste operations are not in taking place in the same area) Waste packages with sources are stored in a manner such that packages are not in contact the floor or interior surface of the building walls. This allows for inspection and control operations and the potential corrosion of packaging/containers is limited. Unconditioned radioactive sources are stored in storage systems ensuring normal operation and minimizing probability of accidents. Their main characteristics are: Compliance and controlled as controlled area Confirmed. Receiving, treatment. Decontamination and conditioning area 160 m2 and storage room 46 m2. Ref Comments No labyrinth system. Only a wall placed in front of entrance to storage room to reduce radiation shine from storage area. To be demonstrated once facility is commissioned. Also to be included in work procedures To be assessed. Storage capacity is greater than current and foreseen needs of management. It ensures source segregation. In this way, periodic inspection and radiological monitoring of the storage building and of the waste drums/packages is facilitated. Total inventory limits to be developed. Its structure resists the maximum load of the sources that are intended to be stored. Maximum load capacities to be demonstrated. Segregation of sources is provided for as part of the receipt procedure. Clear procedures need to be developed for the assessment and handling of unknown sources. 3. Engineering systems ensuring safety for situations of occurrences and accidents 3.1 Floor and wall finish allow easy To be ensured during decontamination. completion of facility and confirmed. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 42 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Item 3.2 3.3 Requirement (Note 1). The segregation of the different areas limits the potential dispersion of any contamination. Compliance No dynamic or static containment systems needed during normal DSRS operations. Evaluation to determine the need, system and procedure to handle and process contaminated DSRS. Extraction hood to be fitted where sources will be removed from their working shields (at the conditioning area) Collection sump for potentially contaminated liquids at the decontamination bay. The sump drains to the collection tanks. Prepare procedure for sampling and release of effluent To be confirmed. Ref Comments In case of a potential surface decontamination using liquids there is a collection system inside the facility that prevents its release to the environment. The system has a retention tank that permits environmental monitoring before releasing to the environment. 3.4 The facility has its own fire detection and fire-fighting equipment. 4. Facility design provides physical security features commensurate with the security threat 4.1 Robust building construction Facility inspection showed with high integrity doors and robust building locks to the treatment and construction with high storage areas. integrity doors and locking systems. To be confirmed during final installation 4.2 Buildings are equipped with To be confirmed intrusion alarms. 4.3 The buildings have vehicle The building has one access points. A separate vehicle access point. personnel door is provided to Personnel entrance is via segregate personnel from the change rooms vehicle movements. between the administrative section and the radiologically controlled areas. 4.4 No windows are provided so as Main Hall is equipped with to improve its shielding and windows at a 6.5 m security performances. height. The windows cannot open and will provide only sunlight. Security enhancements are, however, required specifically on the windows close to second This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 43 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Item Requirement (Note 1). Compliance floor patio. Ref Comments Note 1: Requirements based on IAEA safety standard: WS-G-6.1: Storage of Radioactive waste 10.2 Quantitative Deterministic Assessment of Worker Dose Refer to section 8.2.1 for description and assumed number of actions per year. 10.2.1 Activity 1: Collection of DSRS at Interim Stores Table 4: Collection of DSRS at Interim Stores Operator Groups Operator Actions Exposure Type Exposure Data Dose rate [µSv/h] 1 Loaders(3) Inspection and ID Loading 10.2.2 Whole Body 5 Extremity 70 Whole Body 5 Extremity 70 Justification/Notes Dose rate at 1m from DSRS, see section 9.4 (4) Contact dose rate on DSRS, see section 9.4 (3) Dose rate at 1m from DSRS, see section 9.4 (4) Contact dose rate on DSRS, see section 9.4 (3) Exposure time Time per action [h] Actions per year Annual dose [µSv/a] 0.25 20 25 0.25 20 350 1.75 20 175 1.75 20 2450 Activity 2: Collected DSRS are transported in a dedicated vehicle by 2 drivers from Users and interim storage locations to CNSTN. Table 5: Transport of DSRS Operator Groups Operator Actions Exposure Type Exposure Data Dose rate [µSv/h] 1 Drivers (2) Driving Whole Body 5 Justification/Notes Dose rate in vehicle cab. Based on dose rate at 1m from DSRS, see section 9.4 (4) and assuming 2 units on truck and having increased distance and vehicle body between drivers and sources Exposure time Time per action [h] Actions per year 3 10 Annual dose [µSv/a] 150 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 44 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 10.2.3 Activity 3: Receipt of DSRS at CNSTN Table 6: Receipt of DSRS at CNSTN Operator Groups Operator Actions Exposure Type Exposure Data Dose rate [µSv/h] 1 Operators (2) Off loading Inspection and segregation Whole Body 5 Extremity 70 Whole Body 5 Extremity 70 Whole Body 5 Extremity 70 2 RPO Surveying 10.2.4 Justification/Notes Dose rate at 1m from DSRS, see section 9.4 (4) Contact dose rate on DSRS, see section 9.4 (3) Dose rate at 1m from DSRS, see section 9.4 (4) Contact dose rate on DSRS, see section 9.4 (3) Dose rate at 1m from DSRS, see section 9.4 (4) Contact dose rate on DSRS, see section 9.4 (3) Exposure time Time per action [h] Actions per year Annual dose [µSv/a] 1 20 100 0.1 20 140 0.2 20 20 0.1 20 140 0.2 20 20 0.1 20 140 Activity 4: Temporary Storage of Category 3 Sources and general activities in the CSF. Table 7: Temporary Storage of Cat 3 Sources and general activities in the CSF Operator Groups Operator Actions Exposure Type Exposure Data Dose rate [µSv/h] 1 Operators(2) 2 RPO (1) 10.2.5 Placement of Cat 3 in temporary storage General Inspection, maintenance and cleaning of whole CSF Radiological Inspection & surveying of CSF Whole Body 5 Extremity 70 Whole Body 10 Extremity NA Whole Body 10 Extremity NA Justification/Notes Dose rate at 1m from DSRS, see section 9.4 (4) Contact dose rate on DSRS, see section 9.4 (3) Ambient dose rate, see section 9.4 (2) Ambient dose rate see section 9.4 (2) Exposure time Time per action [h] Actions per year Annual dose [µSv/a] 0.1 20 10 0.1 20 140 8 12 960 4 12 480 Activity 5: Conditioning Campaign 1: Standard Cat 3 Sources Table 8: Conditioning Campaign 1 Operator Groups Operator Actions Exposure Type Exposure Data Dose rate [µSv/h] 1 Operators(2) Handling Whole Body 5 Justification/Notes Dose rate at 1m from DSRS, see section 9.4 (4) Exposure time Time per action [h] Actions per year 0.017 30 Annual dose [µSv/a] 2.55 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 45 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Operator Groups 2 RPO (1) 10.2.6 Operator Actions Dismantling Source Transfer, refer to section 8.2.1 Loading source and shield in container and closing of Storage Container refer to section 8.2.1 Supervision & surveying during conditioning Exposure Type Exposure Data Dose rate [µSv/h] Extremity 70 Whole Body 50 Extremity 70 Whole Body 50 Extremity Whole Body Extremity Justification/Notes Contact dose rate on DSRS, see section 9.4 (3) DR behind shield, see section 9.4 (7) Unshielded doserate see section 9.4 (3) (2) DR behind shield see section 9.4 (7) Unshielded DR see section 9.4 5 (5) Doserate at 1 m on a typical final waste package see section 9.4 (8) 12000 50 Contact doserate on a typical final waste package see section 9.4 (8) 1000 Whole Body 15 Extremity NA Ambient doserate see section 9.4 (1) Exposure time Time per action [h] Actions per year Annual dose [µSv/a] 0.017 30 35.7 0.1 30 150 0.1 30 210 0.01 30 15 0.005 30 1800 0.3 2 33 0.3 2 660 0.5 30 225 Activity 6: Conditioning Campaign 2: Non-Standard & Linear Cat 3 Sources Table 9: Conditioning Campaign 2 Operator Groups Operator Actions Exposure Type Exposure Data Dose rate [µSv/h] Extremity 12000 Whole Body 1200 Extremity 12000 Justification/Notes Dose rate at 1m from DSRS, see section 9.4 (4) Contact dose rate on DSRS, see section 9.4 (3) DR behind shield, see section 9.4 (7) Unshielded DR see section 9.4 (5) Unshielded DR see section 9.4 (6) Unshielded DR see section 9.4 (5) Whole Body 10 Ambient doserate see section 9.4 (2) Extremity NA 1 Handling Operators(2) Dismantling Source Transfer Sources are combined with those in Campaign 1, refer to Whole Body 5 Extremity 70 Whole Body 50 2 RPO (1) Supervision & surveying Annual dose [µSv/a] Exposure time Time per action [h] Actions per year 0.017 3 0.3 0.017 3 3.6 0.17 3 25.5 0.01 3 360 0.01 3 36 0.01 3 300 0.5 3 15 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 46 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 10.2.7 Activity 7: Transfer of Conditioned Waste Packages to the Waste Store including its Surveillance, Inspection and Maintenance Table 10: Transfer of Conditioned Waste Packages to the Waste Store Operator Groups Operator Actions Exposure Type 1 Whole Body Operators(2) Handling and placement into storage room 10.2.8 Extremity Exposure Data Dose rate Justification/Note [µSv/h] s Dose rate at 1m from final package, see 50 section 9.4 (8) Contact dose rate on final package, 1000 see section 9.4 (9) Exposure time Time per action [h] Actions per year Annual dose [µSv/a] 0.3 2 30 0.05 2 100 Worker Dose Summary The maximum worker dose is summarised in the table below. The maximum dose has been obtained reflecting the assumptions that the same individuals conduct the transporter/loader and operator functions and the same RPO conducts the RPO function. Table 11: Worker Dose Summary Operator Groups Loaders/ Transporters Operator Actions Exposure Type Worker Dose Per Activity [uSv/a] 3 4 5 6 7 Whole Body 100 10 3 1 30 Extremity 140 140 36 4 100 Whole Body 150 26 Extremity 210 360 Source Transfer Whole Body 15 36 Extremity 1800 360 Inspection and Maintenance Whole Body 20 Extremity 140 Storage container preparation Whole Body 33 Extremity 660 Supervision and Surveying Whole Body 20 Extremity 140 Inspection & Loading Transport 1 Whole Body 200 Extremity 2800 Whole Body 2 150 Extremity Handling & off loading Dismantling Operators RPO 960 225 15 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 47 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Operator Groups Operator Actions Facility Surveillance Exposure Type Worker Dose Per Activity [uSv/a] 1 2 Whole Body 3 4 5 6 7 480 Extremity The maximum total dose to the Operator/Loader/Transporter is therefore: - Whole body: Extremity: 1.734 mSv/a 6.750 mSv/a The maximum total dose to the Operator (excluding loading/transport) is therefore: - Whole body: Extremity: 1.384 mSv/a 3.950 mSv/a The maximum total dose to the RPO is therefore: - Whole body: Extremity: 0.74 mSv/a 0.14 mSv/a. 10.3 Deterministic Assessment of Worker and Public Dose for Anticipated Operational Occurrences: The scenarios as defined in Section 9.3.2.1 above is assessed by simply calculation. Occurrence scenario 1 The maximum public and additional worker dose is calculated by multiplying the maximum anticipated dose rate of 5 µSv/h from a shielded cat 3 source as used in Table 2 with the exposure times of 1 hour and 30 min for the public and workers respectively: The maximum public dose would therefore be 7.5 µSv or even 22.5 µSv if simultaneously irradiated by 3 sources. The maximum additional dose to the worker would therefore be in the order of 22.5 µSv if the same argument is used. Occurrence scenario 2 The Maximum additional dose to the worker due to the occurrence is calculated by increasing the exposure time of the operator’s source transfer activity as tabled in Table 8 above to 45 minutes. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 48 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA The maximum additional dose to the worker would therefore be; whole body 38 µSv and, assuming that the hands are the whole time behind the work shield, extremity 9000 µSv. Occurrence scenario 3 The Maximum additional dose to the worker due to the occurrence is calculated by increasing the exposure time of the operator’s source transfer activity as tabled Table 9 above from 0.6 minutes to 15 minutes. The maximum additional dose to the worker would therefore be; whole body 264 µSv and extremity 2640 µSv. 10.4 The following other accident scenarios will be considered in the Tunisian Safety Assessment: Accident Scenario 1 The maximum public and additional worker doses projected for the scenario as defined in Section 9.3.2.2 above are derived based on the assumptions, calculations and modelling indicated in the table below: Table 12: Accident scenario 1 Receptors Actions Firefighting Personnel Firefighting Exposure type Whole body Internal dose Public Living close to area of accident Operators Clean-up Internal radiation and exposure from cloud & ground shine Whole body Internal dose Exposure data Units Justification/ Notes 500 µSv/h Ambient dose rate [1] 1E6 Bq/m3 Activity concentration [2] Exposure parameters Time per Other/Units [x] action [h] 0.3 150 0.3 Respirator. Eff. 0% Breathing rate: 1.2 m3/h AMAD: 1um DCF: 4.8E-9 Sv/Bq Dispersion and dose modelled with Hotspot assuming a ground level release, see Appendix A for Hot spot inputs and results [3] 1728 50 µSv/h 800 2E7 Bq/m2 Ambient dose rate [4] Surface contamination [5] 16 16 Respirator. Eff. 0% Breathing rate 1.2 m3/h AMAD 1um DCF: 4.8E-9 Sv/Bq Dose [µSv] 0.967 1843 Notes: [1]: Elevated ambient dose rate due to 50mCi Cs-137 damaged and exposed source and activity release into the air. Assume conservatively ambient dose rate of 500 µSv/h based on dose rate from exposed source and activity released into the air (dose rate 0.5m from 50mCi Cs-137 source is 560 µSv/h) This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 49 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA [2]: Projected airborne activity concentration levels calculated on the assumption that 10% of 50mCi Cs-137 source is dispersed homogeneously inside the facility with a total volume of 200m3 [3]: Hotspot dispersion model assuming 10mCi (20% of 50mCi source) Cs-137 is released into the atmosphere, long term exposure (4 days), conservative metrological conditions and using highest exposure in dispersion plume (maximum TED). [4]: Elevated ambient dose rate due to 5mCi Cs-137 spread as contamination over the whole area to be cleaned. Assume conservatively ambient dose rate of 50 µSv/h based on dose rate from activity spread in area (dose rate 0.5m from 5mCi Cs-137 source is 56 µSv/h) [5]: Maximum projected surface contamination levels calculated on the assumption that the 5mCi (10%) which was released into the facility, has settled homogeneously on a 10m2 area. Accident scenario 2 The maximum public dose for this scenario as defined in Section 9.3.2.2 above (second scenario) are derived based on the assumptions, calculations and modelling indicated in the table below: Table 13: Accident scenario 2 Receptors Actions Exposure type Public Living close to area of accident Internal radiation and exposure from cloud & ground shine Exposure data Exposure parameters Units Justification/ Time per Other/Units [x] Notes action [h] Dispersion and dose modelled with Hotspot assuming a ground level release see Appendix B for Hot spot inputs and results [1] Dose [µSv] 0.193 Notes: [1]: Hotspot dispersion model assuming 2mCi (10% of two 10mCi sources) Cs-137 is released into the atmosphere, long term exposure (4 days), conservative metrological conditions and using highest exposure in dispersion plume (maximum TED). Accident scenario 3 The maximum Operator and RPO doses projected for the occurrence and scenario as defined in section 9.3.2.2 above are derived based on the assumptions, calculations and modelling indicated in the table below: Table 14: Accident scenario 2 Receptors Operator Operator RPO Actions Source handling Sources recovery Supervision Exposure type Exposure data Units Whole body 5000 µSv/h Whole body 2222 µSv/h Whole body 556 µSv/h Justification/ Notes Calculated dose rate at 1 m [1] Calculated dose rate at 1.5 m [2] Calculated dose rate at 3 m [3] Exposure parameters Time per Other/Units [x] action [h] 0.0167 Dose [µSv] 0.5 1111 0.5 278 83 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 50 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Notes: [1]: Dose rate at 1 m calculated for an unshielded 50mCi Cs-137 source using a specific gamma ray constant of 0.33 R.m2/Ci.h. The dose rate was adjusted for 30 sources by assuming a linear relationship between dose rate and activity (Simplified point source geometry) [2]: Dose rate at 1.5 m calculated for 30 unshielded 50mCi Cs-137 sources using the dose rate at 1 m, and inverse square law. [3]: Dose rate at 3 m calculated for 30 unshielded 50mCi Cs-137 sources using the dose rate at 1 m, and inverse square law. The maximum total doses to the Operator and RPO is therefore: Whole body: 1.2 mSv and 0.28 mSv respectively. Note that if Co-60 sources with the same activity are assumed that the approximate doses to the Operator and RPO would be 4.8 mSv and 1.1 mSv respectively. 10.5 Comparative Dose Assessment: SAFRAN A dose assessment for the DSRS activities at the CNSTN CSF was also performed using the SAFRAN version 2.1.4.0 dose assessment tool. The purposes of this assessment was to enable a comparison between the simple spreadsheet assessment as performed in Section 10.2 above and the SAFRAN tool. The SAFRAN dose assessment was performed only for the Receiving, Interim storage, Conditioning and Longer term storage activities. The results of the SAFRAN assessment are provided in table attached as Appendix D. The results of the SAFRAN assessment for the respective activities assessed are the same as calculated in the tables above in Section 10.2. 10.6 Optimization of Protection: Assessment The summary of the outcome of the quantitative assessment of the radiological consequence of normal operations, anticipated operational and other occurrences as well as comments and recommendations regarding the optimization of protection, are covered in the table below. Table 15: Optimization of Protection: Assessment Occupatio nal Group/ Receptor Dose /Dose Rate [µSv/µSv/a] Whole ExtreBody/ mities ED Comments Recommendations 1. Normal Operation: Quantitative Deterministic Assessment of Worker Dose Operator/ 1734 This assumes that the Ensure that the applicable 6750 µSv/a Loader/ µSv/a operator is experienced personnel is aware of the This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 51 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Occupatio nal Group/ Transporter Receptor Dose /Dose Rate [µSv/µSv/a] Comments and trained in performing the tasks. If the level of conservatism associated with the dose assessment is considered, the annual exposure to workers is low which limits the margin for further optimization of protection. Most of the exposure is due to the source transfer, which is a needed and justified action. Recommendations associated risks and is experienced in the tasks. If not such personnel is available, the conditioning of sources (which has a higher risk of exposure) should be performed with expert support or supervision. Implementation of a formal operational optimization programme where actual doses are measured and specific reduction strategies are considered and implemented Define source transfer as a safety critical action and consider design and procedures to reduce exposure potential None RPO invigilation is justified i.t.o. dose limitation and 740 RPO 140 µSv/a control. RPO dose is below µSv/a current optimization trigger level. 2. Anticipated Operational Occurrences: Quantitative Deterministic Assessment of Worker and Public Dose : Occurrence 1 Operator/L Exposure levels are below Actions to ensure compliance oader/ 22.5 µSv optimization trigger levels to the transport regulations. Transporter and sufficient control is inherent to the compliance Public 22.5 µSv to the transport regulations 3. Anticipated Operational Occurrences: Quantitative Deterministic Assessment of Worker and Public Dose : Occurrence 2 Evaluate the possibility to install a radiation alarm Operator/ Expose levels are low but system with an alarm set Loader/ 38 µSv 9000 µSv possible to prevent by point of about 150 µSv/h Transporter simple design changes. (response, testing and maintenance procedures) 4. Anticipated Operational Occurrences: Quantitative Deterministic Assessment of Worker and Public Dose : Occurrence 3 Evaluate the possibility to install a radiation alarm system with an alarm set point of about 150 µSv/h Operator/ Possible to prevent (response, testing and Loader/ 264 µSv 2640 µSv exposure by simple design maintenance procedures) Transporter and operational changes. Formalised procedure to ensure the prior evaluation of unknown/ nonstandard sources and planning of its dismantling 5. Other Occurrences: Quantitative Deterministic Assessment of Worker and Public Dose : Accident Scenario 1 Fire Dose mainly due to Initiate a fire and fire fighting 2028 µSv external radiation. Dose protection system evaluation Personnel due to contamination and of the areas. dispersion of beta gamma Assess the possibility to store Public 0.967 µSv emitters is low. Possible to unconditioned sources in which is prevent exposure by simple vaults or other fire proof insignificant This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 52 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Occupatio nal Group/ Receptor Dose /Dose Rate [µSv/µSv/a] Comments Recommendations design and operational changes to prevent fires and to mitigate the consequences of fires. system. Review procedures to ensure Operator/ housekeeping and storage Loader/ 800 µSv practices that are aligned with Transporter fire prevention and control measures. 6. Other Occurrences: Quantitative Deterministic Assessment of Worker and Public Dose : Accident Scenario 2 Exposure levels are below • Actions to ensure compliance 0.193 µSv optimization trigger levels to the transport regulations Public which is and sufficient control is insignificant inherent to the compliance to the transport regulations 7. Other Occurrences: Quantitative Deterministic Assessment of Worker and RPO Dose : Accident Scenario 3 Dose mainly due to • Review design of source external radiation. Possible container Operator 1200 µSv to prevent exposure by • Review the source container prevent falling and or loss handling procedure of sources in the event of a • Ensure that ALARA review is fall event. Dose could also prescribed by intervention RPO 280 µSv be reduced by using more procedure in order to operators during minimize individual dose. intervention 10.7 Non-radiological Hazard Assessment The following non-radiological hazards are relevant to the operation of the Waste management facilities at CNSTN: Conventional Hazards: Manual handling of heavy objects, overhead loads, using of driven and manual tools, working on elevated heights. These hazards are managed by a general awareness of the hazards, training and appointment and the compulsory use of personal protective equipment while performing specific activities. Hazardous chemical substances: May include flammable and toxic chemical stored and used in the waste treatment facility or the presence of other hazardous/irritant substances such as cement, dust, lead, asbestos, etc. Hazardous chemical substances are controlled by maintaining inventories of such materials, proper storage practices, work procedures that prescribe the requirements for the safe handling of such substance e.g. personal protective equipment requirements. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 53 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 10.8 Assessment of the Implemented Waste Management Practice The outcome of the quantitative assessment of the current and future waste management practice to be implemented by CNSTN is tabled below: Table 16: Quantitative Assessment: Current and Future Waste Management Practices Item Requirement Compliance Comments Ref 1. Clearly defined responsibilities for waste management. 2. Implementation of the principles of waste minimization and avoidance, namely, re-use or reprocessing of waste, return to supplier, safe and secure storage and conditioning and final disposal of waste. 3. Hazards and the generation of secondary waste, associated with all waste management operations (routine and ad hoc) are known, monitored, projected and managed by due management processes. 4. Interdependencies between the various steps of waste management are known and managed. Waste acceptance The existing Legal Framework of Tunisia is outdated. Tunisia is however in the process of drafting a new National Nuclear Law that will specify the responsibilities for the generation and management of radioactive waste. The proposed CSF currently under construction at CNSTN and planned operation of the waste management facility demonstrates intent and commitment. Principles will be defined in the new Legal Framework and implemented in the case of DSRS to the point of conditioning. No final disposal option is available. A Radioactive Waste Management Agency will be constituted under the new Nuclear Law CNRP is currently responsible for the National Source Inventory and CNSTN is responsible for their own inventory. RP requirements in terms of this requirement are being implemented. There is no treatment of standard DSRS as the proposed CSF is still under construction. CNRP does however condition DSRS at the end-users where DSRS is stored inside their working shields in a cement matrix. Conditioning exercises are planned to mitigate exposure. Facilities to treat nonstandard sources or deviating e.g. contaminated sources do not yet exist. No procedures to assess and plan the handling of non-standard exist. Future waste management practices will be performed as described in Section 9.1.1.2. Compliance to be demonstrated once new facility becomes operational. No written conditioning specification or a WAC for the proposed storage facility exists as yet. It was also not indicated how the current CNRP Section 6.1.3 Section 6 Section 8.2 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 54 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Item 5. 6. Requirement Compliance Comments criteria are defined, waste management activities and the outputs of such activities are aligned with set waste acceptance criteria. Interim storage of DSRS will only take place inside proper containment such as the original working shields or another type of suitable containment. conditioning actions and specification are aligned with future disposal options (allows for recovery of DSRS from waste packages). Conditioned DSRS will be stored in a dedicated storage area with passive safety features and adequate access control. DSRS in their original working shields (as per the national inventory) is stored at the end-users as single units or in a cement matrix waste container. DSRS stored in future in centralised waste management facility should be stored inside working shields or other suitable containment. Need to be demonstrated. . To be confirmed. Ref Section 8.3 Section 8.3 and 6.4 10.9 Management System Assessment The outcome of the quantitative assessment of only the main requirements of an integrated management system as implemented by CNSTN is tabled below: Table 17: Quantitative Assessment: Integrated Management System Item Requirement Compliance Comments 1. 2. 3. A written and approved integrated management system is maintained to ensure a sustained level of safety during the operational phase of the facilities. The Quality Assurance part of the integrated management system inter alia covers: Quality policy and objectives Organisation and responsibilities Documentation, waste tracking and record keeping Product realisation and work procedures Worker training and appointment Change control of procedure and facilities Non-conformance and event management Auditing and system review An RP programme exist and inter alia covers: RP organisation, training and No written and approved management system has been developed as yet. Not yet existing CNSTN has an existing RP Programme for the proposed CSF. Needs to be updated. Ref This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 55 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Item 4. 10.10 Requirement appointment Zone classification, criteria and access control Workplace monitoring and surveillance Personnel monitoring and medical surveillance Environmental monitoring RP instrumentation control Clearance/exemption surveillance and control The integrated management system inter alia covers: An approved WAC for receipt of DSRS at the waste treatment facility An approved WAC for receipt of DSRS waste packages at the waste storage facility Procedure in which all operational limitations and conditions associated with the facilities, their performance criteria and how and at what interval their performance will be assessed and recorded, are listed Compliance Comments Ref Proposed CSF still under construction; therefore no existing WAC . Assessment of Uncertainties The outcome of a provisional quantitative assessment of uncertainties related to the safety case is presented in the table below: Table 18: Provisional Quantitative Assessment: Safety Case Uncertainties Comments/ Ref Item Uncertainty Recommendations 1. 2. Uncertainty in the source term used in the safety assessment. The source term is defined for cat 3 sources and specifically for beta/ gamma emitters such as Cs-137 and Co-60. The impact of normal operations and occurrences could be significantly higher if higher activity sources or alpha emitting sources have been considered. The critical pathway in the case of alpha emitting radionuclides for contamination scenarios is internal radiation. Uncertainty regarding the dose rate information used in the safety assessment. Although it was aimed The operational limits and conditions of the operational waste treatment facility should limit the range of source that could be received under the current authorization. The facility WAC should state the limits and conditions as mentioned above and include a process and authorization requirements for the receipt of any unknown sources of sources outside the facility WAC. Confirmatory monitoring should be performed and used to verify the dose rate assumptions or be used This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 56 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA to use conservative data, the exposure data used for the various exposure scenarios is not based on scientific arguments, measurement or modelling results. No certainty as to whether the CNSTN DSRS Management Facility will in fact become the national centralised facility although CNRP and CNSTN both support that principle. Although the main methodologies for management of DSRS do not differ much and is based on standard practice, the specific activities (procedural steps) within the methodologies may be different than what was assumed for the safety assessment. 3. 4. 10.11 Comments/ Recommendations Uncertainty Item Ref as bases to update exposure scenarios and data. Confirm this proposal. Safety Case will have to be updated if not the case. The specific procedures should be developed and tested to ensure its suitability for CNSTN. The safety assessment should be updated to reflect this. Procedures should also align with best international practice. Assessment of possible Public exposures Exposure to the public is only possible due to the following: - Elevated radiation levels outside the facility security fence. Radiation levels will be routinely monitored by the facility RPO to confirm that radiation levels remains less than 10 x natural background levels (or any limit prescribed by the regulator), refer to section 8.2.2.2. Thus public will not receive elevated exposures. - Severe accidents at the facility or during the transport of DSRS to the facility. These have been evaluated in section 10.3. The resulting possible public exposure during any of these events is insignificant. 10.12 Assessment of possible environmental pathways Liquid If contaminated liquid is released into the environment it could contaminate the area and have possible later impact on the public being exposed to this soil. The release of effluent from the facility is for the following reasons highly unlikely: - No contaminated effluent is generated during the routine operation of the facility. The facility is developed for the storages of sealed radioactive sources. The probability of a source to start leaking during storage and conditioning is very small. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 57 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA - Before any waste package is accepted in the storage facility, it will be checked by the facility RPO for any sign of contamination. Should it be contaminated, the waste package will be decontaminated and sealed. - If a contaminated item or leaking source is received (very unlikely) and have to be decontaminated, these will be handled in the decontamination bay. This bay is located inside the receiving and treatment hall. This area is installed with a drainage system, which will divert any water from this area into dedicated effluent tanks. In addition standard practice during decontamination and cleaning is to use as little as possible water (minimisation of secondary waste) - Routine radiation and contamination surveys are done in the facility by the facility RPO. Should presence of any contamination be detected, the applicable area or DSRS will be decontaminated Gaseous Gaseous release into the environment and exposing the public is only possible during an accident scenario. These have been evaluated in section 10.3. The resulting possible public exposure during any of these events is insignificant. 10.13 Waste Management Should any solid waste be generated during the conditioning of DSRS (e.g. protective clothing, gloves, overshoes, cleaning papers) this shall be kept separate and accumulated in a waste drum, which will be sealed when not in use. Any waste generated or accumulated during the clean-up of a possible event where a source was leaking or contamination was spread, the waste shall be accumulated in waste drums. Record shall be kept of the waste drums and their applicable content. The drum shall be regarded as containing radiation and kept in the CSF. 11.0 HUMAN RESOURCES The management team of the CNSTN is responsible to ensure that all the personnel involved in any of the transport, operation, inspection and control activities at the Centralized Storage Facility are properly trained and experienced in the applicable activities and associated risks. Evidence of the applicable training shall be kept as a QA record. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 58 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA All the activities shall be done by the applicable personnel in accordance with documented and approved work procedures. All the personnel shall be registered, trained and controlled as radiation workers. The following trained personnel would be required: - Radiation Protection Officer - Facility operators 12.0 IDENTIFICATION OF FACILITY SPECIFIC LIMITS AND CONDITIONS Based on the safety assessment, the following facility limitation and conditions are derived: No neutron sources will be conditioned. Current Tunisian inventory does not include many neutron sources. These source units shall only be safely stored. The radiation outside the facility depends on various factors, which include: external wall thickness and density, external radiation on packages, nuclides, package design, total facility inventory and storage configuration. Due to the number of factors, it is not possible to determine the maximum nuclide and activity inventory of the facility which will ensure that the radiation outside the facility will be acceptable for possible public exposure. For this reason routine RPO surveys outside the facility are required. These then needs to confirm that radiation levels remains less than 10 x natural background levels (or any limit prescribed by the regulator). Should the surveys show elevated levels, applicable corrective actions should be implemented inside the CSF. The assessment assumed 30 standard and 3 non-standard DSRS to be conditioned per year. These activities contributes the most to personnel exposure. The current foreseen exposure is relatively low. After actual operation, these could be reconsidered and the number of cappains increased and specified as limiting condition.. Specify Sources i.t.o. radionuclides and activity limits that may be received and processed as standard and non-standard campaigns. A process that includes evaluation and authorization of receipt, handling and treatment of sources other than the specified sources. The storage location and maximum inventory of DSRS in such locations in the waste treatment facility should be specified and controlled. The maximum localized and ambient dose rates inside the waste treatment and facility should be specified and should not be in excess 250 and 25 µSv/h respectively (general limits applied for controlled areas). The maximum inventory for the storage facility needs to be derived and specified This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 59 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA The maximum localized and ambient dose rates inside the waste storage facility, in operator zones should be specified and should not be in excess 250 and 25 µSv/h respectively. The maximum dose rate outside any of the waste management facilities should not be in excess of 2.5 µSv/h. Annual reporting of facility operations and RP surveillance data to the regulatory body. 13.0 INTEGRATION OF SAFETY ARGUMENTS The provisional synthesis of safety arguments below should be considered within the scope of the safety case i.e. constructed and operational stage facilities; 13.1 Facility Design and Engineering Although a range of facility design, engineering and construction related aspects have been identified as relevant to safety, it still needs to be obtained/demonstrated, the proposed CSF currently under construction seems robust with features that indicate that safety and security have been considered. Unresolved issues related to facility design and engineering including management systems to ensure a sustained level of safety (e.g. maintenance and change management) are covered in Section 15.0 below. 13.2 Facility Operation The safety assessment indicates that the facility can be operated well within safety criteria as far as DSRS activities are considered. The safety assessment may also be used as basis to increase the extent and range of operations related to high activity DSRS taking cognisance of an acceptable margin that needs to be maintained. The assessment of occurrences also indicates consequences well within safety and risk criteria. (The equivalent risks of the occurrences could be demonstrated as low and below 10-5 per year even at frequencies of 10-1 to 10-2 per year). Uncertainties exist mainly regarding source term assumptions and some scientific data. Unresolved issues (Section 15.0) included continued action the verify assumptions and scientific data. Some facility specific limits and conditions have also been recommended in order to mitigate some uncertainties. 13.3 Optimization of protection The margin for optimization of protection associated with the DSRS activities is limited in view of the relative low consequences and conservatism of assumptions made. Some facility design and procedural changes could however reconsider for further optimization of protection. An operational optimization of This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 60 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA protection program, that is based on activity specific RP surveillance, personnel dosimetry results and scheduled optimization review sessions, is recommended. 13.4 Waste Management Practise Good waste management practice is generally evident from the intent of the legal framework, organisational arrangements and defined responsibilities, to establish waste management facilities and the waste management facility operations. The interdependencies amongst the various waste management steps seem to be considered to the point of waste treatment. The alignment between conditioning, conditioning specification, storage and disposal is not clear nor has any written and approved WAC been made available. Recommendations regarding unresolved issues are covered in Section 15.0 below. 13.5 Integrated Management System Although some management systems and procedures have been implemented no evidence of such written and approved system were supplied. Management of unresolved issues as covered in Section 15.0 below, addresses recommendations regarding the development of an integrated management system. 13.6 Uncertainties The provisionally identified uncertainties is neither of such a nature nor extent that the associated detriment in confidence in the safety case would result in the recommendation of drastic measures. Uncertainties are manageable by setting specific facility limits and conditions, preparing WAC and by implementation of some confirmatory monitoring plans. The management of unresolved issues as covered in Section 15.0 below, covers management of uncertainties. 14.0 COMPARISON WITH SAFETY CRITERIA AND CONCLUSIONS The Quantitative safety assessment results as reflected in Section 10.5 above, is well within the safety criteria as listed in Section 6.3.1 for workers and Section 6.3.2 for the public. The safety case for the DSRS operations in the waste management facilities at CNSTN is supported subject to a formal plan and schedule to address the identified unresolved issues as covered in Section 15.0 below. This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 61 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 15.0 ASPECTS REQUIRING CLARIFICATION AND RECOMMENDATION The identified aspects requiring further clarification with commensurate management recommendations are tabled below: Table 19: Aspects Requiring Clarification/Recommendations Item Aspects Requiring Clarification Recommendation 1. Tunisian Legal and regulatory Framework During the preparation of this case, a draft National To update section 6.1.3 of the report to 1.1 Nuclear Law for Tunisia was in the process of being reviewed for signature and to be promulgated by government. 2. Basic Engineering Analyses A number of unresolved issued and gaps have been 2.1 identified in the basic engineering analyses as listed in section 10.1. that needs to be resolved or managed. 3. Optimization of Protection Optimization Normal Operation related exposure 3.1 3.2 Optimization of occurrence related exposure. include the provisions of the new legislation Develop a strategy and plan to obtain relevant information and documentation. If it is not possible to obtain certain information, further justification should be considered. The plan should make provision for the revision of the safety case. Development and implementation of a formal operational optimization (ALARA) programme where actual doses are measured and specific reduction strategies are considered and implemented. Define source transfer as a safety critical action and review design and procedures to reduce exposure potential. • • • Actions/audit to ensure compliance to the transport regulations. Evaluate the possibility to install a radiation alarm system with an alarm set point of about 150 µSv/h (response, testing and maintenance procedures). Develop and implement a procedure to ensure the prior evaluation of unknown/ nonstandard sources and planning of its storage and treatment. Initiate a fire and fire protection system evaluation of the areas if not installed before commissioning. Assess the possibility to store unconditioned sources in vaults or other fire proof systems. Develop procedures (inspection and testing) to ensure housekeeping and storage practices relating to fire prevention and control are established This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 62 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Item Aspects Requiring Clarification Recommendation and maintained. 4. Non-Radiological Hazards Comprehensive assessment of non-radiological 4.1 hazards. 5. Implemented Waste Management Practice WAC. 5.1 5.2 Interdependencies related to disposal 6. Integrated Management System No written and approved management system 6.1 documents have been provided. • 7. Management of Uncertainties Uncertainties related to source term. 7.1 7.2 Uncertainties regarding dose rate assumption. 7.3 Uncertainties regarding the specific procedural steps in the DSRS management process. 8. Facility Specific Limits and Conditions Procedure for defining and management of facility 8.1 specific limits and conditions 16.0 Plan, schedule and conduct a comprehensive non radiological hazard assessment. (Covered in integrated management system 6. below) National waste management plan to make provision for disposal- could be a longer term action but commitments related to disposal are necessary. Plan and schedule an integrated management system review that is focussed the main requirements as listed in the table in 10.8 above. • (Covered by Facility limits and condition in 8. below and be actions to develop WAC in as covered in 6. Above) Develop and implement a confirmatory monitoring plan to verify the dose rate assumptions once facility becomes operational. This could be used as bases to update exposure scenarios and data. Develop procedures for each management step and test suitability for the CNSTN facility.. Development of a procedure that lists the agreed limits and conditions as applicable to the various facilities and activities as recommended in section 11. Above. The procedure should include the specified limits and conditions, how and when and by whom compliance/ performance will be verified as well as the related recording and reporting requirements. APPENDIX A: HOTSPOT OUTPUT FOR ACCIDENT SCENARIO 1 HotSpot Version 3.0.2 General Fire Nov 21, 2014 07:53 AM Source Material Material-at-Risk (MAR) Damage Ratio (DR) Airborne Fraction (ARF) Respirable Fraction (RF) Leakpath Factor (LPF) Respirable Source Term : : : : : : : Cs-137 F 30.0y 1.8500E+09 Bq 1.00 0.200 1.000 1.000 3.70E+08 Bq This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 63 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Non-respirable Source Term Release Radius Cloud Top Physical Height of Fire Effective Release Height Wind Speed (h=10 m) Avg Wind Speed (h=H-eff) Stability Class Respirable Dep. Vel. Non-respirable Dep. Vel. Receptor Height Inversion Layer Height Sample Time Breathing Rate Distance Coordinates : : : : : : : : : : : : : : : 0.00E+00 Bq 1m 10 m 5m 8.52 m 2.00 m/s 1.95 m/s D 0.30 cm/s 8.00 cm/s 1.5 m None 10.000 min 3.33E-04 m3/sec All distances are on the Plume Centerline Maximum Dose Distance Maximum TED Inner Contour Dose Middle Contour Dose Outer Contour Dose Exceeds Inner Dose Out To Exceeds Middle Dose Out To Exceeds Outer Dose Out To : : : : : : : : 0.091 km 9.67E-07 Sv 1.00E-10 Sv 1.00E-11 Sv 1.00E-12 Sv 71 km > 200 km > 200 km FGR-13 Dose Conversion Data - Total Effective Dose (TED) Include Plume Passage Inhalation and Submersion Include Ground Shine (Weathering Correction Factor : None) Include Resuspension (Resuspension Factor : NCRP Report No. 129) Exposure Window:(Start: 0.00 days; Duration: 4.00 days) [100% stay time]. Initial Deposition and Dose Rate shown Ground Roughness Correction Factor: 1.000 Distance TED km 0.100 0.200 0.300 0.400 0.500 1.000 2.000 (Sv) 9.6E-07 5.2E-07 2.9E-07 1.9E-07 1.3E-07 4.1E-08 1.3E-08 RESPIRABLE TIME-INTEGRATED AIR CONCENTRATION (Bq-sec)/m3 4.5E+05 2.4E+05 1.4E+05 8.6E+04 6.0E+04 1.9E+04 6.3E+03 GROUND SURFACE DEPOSITION GROUND SHINE DOSE RATE (kBq/m2 1.3E+00 7.3E-01 4.1E-01 2.6E-01 1.8E-01 5.7E-02 1.9E-02 (Sv/hr) 2.6E-09 1.5E-09 8.1E-10 5.1E-10 3.6E-10 1.1E-10 3.7E-11 ARRIVAL TIME (hour:min) <00:01 00:01 00:02 00:03 00:04 00:08 00:10 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 64 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 65 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 17.0 APPENDIX B: HOTSPOT OUTPUT FOR ACCIDENT SCENARIO 2 HotSpot Version 3.0.2 General Fire Nov 21, 2014 07:19 AM Source Material Material-at-Risk (MAR) Damage Ratio (DR) Airborne Fraction (ARF) Respirable Fraction (RF) Leakpath Factor (LPF) Respirable Source Term Non-respirable Source Term Release Radius Cloud Top Physical Height of Fire Effective Release Height Wind Speed (h=10 m) Avg Wind Speed (h=H-eff) Stability Class Respirable Dep. Vel. Non-respirable Dep. Vel. Receptor Height Inversion Layer Height Sample Time Breathing Rate Distance Coordinates : Cs-137 F 30.0y : 7.4000E+08 Bq : 1.00 : 0.100 : 1.000 : 1.000 : 7.40E+07 Bq : 0.00E+00 Bq :1m : 10 m :5m : 8.52 m : 2.00 m/s : 1.95 m/s :D : 0.30 cm/s : 8.00 cm/s : 1.5 m : None : 10.000 min : 3.33E-04 m3/sec : All distances are on the Plume Centerline Maximum Dose Distance Maximum TED Inner Contour Dose Middle Contour Dose Outer Contour Dose Exceeds Inner Dose Out To Exceeds Middle Dose Out To Exceeds Outer Dose Out To : : : : : : : : 0.091 km 1.93E-07 Sv 1.00E-10 Sv 1.00E-11 Sv 1.00E-12 Sv 20 km 122 km > 200 km FGR-13 Dose Conversion Data - Total Effective Dose (TED) Include Plume Passage Inhalation and Submersion Include Ground Shine (Weathering Correction Factor : None) Include Resuspension (Resuspension Factor : NCRP Report No. 129) Exposure Window:(Start: 0.00 days; Duration: 4.00 days) [100% stay time]. Initial Deposition and Dose Rate shown Ground Roughness Correction Factor: 1.000 Distance TED km 0.100 0.200 0.300 0.400 0.500 1.000 2.000 (Sv) 1.9E-07 1.0E-07 5.9E-08 3.7E-08 2.6E-08 8.2E-09 2.7E-09 RESPIRABLE TIME-INTEGRATED AIR CONCENTRATION (Bq-sec)/m3 9.0E+04 4.9E+04 2.7E+04 1.7E+04 1.2E+04 3.8E+03 1.3E+03 GROUND SURFACE DEPOSITION GROUND SHINE DOSE RATE (kBq/m2 2.6E-01 1.5E-01 8.2E-02 5.2E-02 3.6E-02 1.1E-02 3.8E-03 (Sv/hr) 5.2E-10 2.9E-10 1.6E-10 1.0E-10 7.1E-11 2.3E-11 7.4E-12 ARRIVAL TIME (hour:min) <00:01 00:01 00:02 00:03 00:04 00:08 00:17 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 66 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 67 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 18.0 APPENDIX C: NATIONAL INVENTORY (CNRP) Nature du radioelement Cs137 Cs137 Cs137 CS137 Cs137 Cs137 Co 60 Co 60 Co 60 Co 60 Co 60 Co 60 Co 60 Co 60 yb169 yb169 Ra/Be Ra/Be Ra/Be Cs137 Irt 92(2 sources) Ir192 in 92 Ir192 Co60 Co60 Co60 Co60 Co60 Co60 Co60 Co60 Co60 AmBe AmBe Cs+AmBe Cs+AmBe Co60 Cs137 Co60 Co60 Pm147 Pm147 CS137 Cs137 Cs137 Activite N° de la serie / type de la source 119 221 234 505 I 7906 9333 36 269 AS537 AS538 NH012 Date de mesure de I'activite 9,9uCi 7,51 Ci 15uCi 3uCi 2,6Ci 3mCi 4,55mCi 1,13mCi 20,15 mCi 9,85mCi 30Ci 7,33Ci 54,6mCi 2,1 mCi 3Ci 3Ci 5mCi 30mCi 1mCi 8,73 Ci 1971 23/02/1981 13/09/1963 12/09/1963 01/03/1981 01/03/1981 03/02/1963 26/02/1963 15/02/1963 23/01/1963 20/04/1978 01/02/1992 15/02/1963 28/02/1963 17/08/1976 17/09/1976 30/07/1962 01/01/1973 01/01/1973 04/10/1973 ? provenance de la Russie AG30-01 AG30-02 AG30-03 AG30-04 AG30-05 AG30-06 AG30-07 AG30-08 AG100-01 Solo20 Solo25 CPN Solo25 Irradiateur QG20 QG100 92Ci =0Ci =0Ci 20mCi 20mCi 20mCi 20mCi 20mCi 20mCi 20mCi 20mCi 60mCi 10mCi 40mCi 10mCi+50 mCi 10mCi+50 mCi 4500Ci ? ? 250nCi 9,25MBq 27mCi 12,3Ci 10mCi 16/05/1979 01/01/1982 Jan-82 1976 1976 1976 1976 1976 1976 1976 1976 1976 07/02/1981 12/12/1968 ? ? 1984 1989 1982 1981 1993 Periode 30ans 30ans 30ans 30ans 30ans 30ans 5ans 5ans 5ans 5ans 5ans 5ans 5ans 5ans 30ans This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 68 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA Cs137 CS137 Cs137 Cs137Am241Be Am241 Am241 C06O Cs137 Cs137Am241Be P32 Ra226 Ra226 Ra226 C06O Cs137 Cs137 Cs137 Cs137 ? Am241 Am241 Cs137 Cs137 Cs137 Cs137 Cs137 Cs137 Cs137 Cs137 Cs137 C06O Cs137 ? Cs137 Ca45 Cs137 Pm147 Na22 Cs134 Nitrate de thorium Gd153 Thalium170 Zn65 Cs137 Eu152 Ag110 Cerium 139 Sr90 TROXLER 10mCi 10mCi 10mCi 7,3mCi-40mCi 199 3 199 199 3 1981-19803 TROXLER 100mCi 100mCi 76,3mCi 2,95Ci 8,8mCi-40mCi 198 198 5 5 03/12/197 03/12/197 9 16/9/819 16/10/81 05/10/199 ? 8 ? ? ? Nov85 Jan86 Nov85 NovOct85 80 Paratonnerre Paratonnerre Paratonnerre ? bascule nucleaire-2016GG bascule nucleaire-2012GG bascule nucleaire-1916GG bascule nucleaire-2006GG jauge de niveau-AG30-3170 Paratonnerre-HELITA AMH5 335/63 Paratonnerre-HELITA AMH5 335/64 bascule nucleaire-2041GG bascule nucleaire-2032GG densimetre -AF37 bascule nucleaire- B360 bascule nucleaire 2040GG jauge de niveau -1805 jauge de niveau -1800 densimetre -DG5 densimetre - DG5 jauge de niveau - 48 densimetre - DG5 densimetre densimetre ? ? 370MBq/ml 1,64mCi 1,64mCi 1,64mCi 0,750mCi 0,750mCi 109mCi 200mC i 789mCi 202mC i 20mCi 289mC ?i 0,0374 GBq 0,037G Bq 0,037G Bq 1mCi ? 1mCi 1mCi Jan86 Jan86 Sep80 Jan86 Jan74 Jan08/11/197 74 7 08/11/197 7 08/11/199 0 31/10/199 0 01/10/198 8 ? Jun88 Jun88 source etalon 2sources etalon 0,1 mCi 05/06/196 9 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 1 Page No.: Page 69 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 19.0 APPENDIX D: CNSTN INVENTORY A0 At RN Q A0 (KBq) (Ci) At (KBq) (Ci) Origin Nature Ray T (an) Da N.R Co-60 1 3,7 E+12 0,99E+05 6,90E+11 1,86E+04 CBI Solid γ 5,27 mars-99 1001 Co-60 1 6,66E+11 1,80E+04 1,98E+11 5,34E+03 Hongrie Solid γ 5,27 oct.-01 1002 Co-60-cs137 1 1,48E+01 4,00E-07 1,01E+01 2,74E-07 ST Solid γ 30,16 juin-95 1003 Cf-252 1 8,70E+02 2,35E-05 1,36E+01 3,68E-07 Canberra Solid η 2,64 Mar-96 1004 C-14/H-3 1 1,70E+02 4,60E-06 7,54E-21 2,04E-28 CMI Solid β 1,266 Sep-97 1005 Am-241 1 5,03E+02 1,36E-05 6,65E-02 1,80E-09 CMI Solid α 432,2 Sep-97 1006 Co-60 1 5,06E+02 1,37E-05 4,92E+02 1,33E-05 CMI Solid γ 5,27 Sep-97 1007 Cs-137 1 4,68E+02 1,27E-05 7,57E+01 2,05E-06 CMI Solid γ 30,2 Sep-97 1008 Na-22 1 5,22E+02 1,41E-05 3,38E+02 9,13E-06 CMI Solid γ 2,6 Sep-97 1009 Pu-236 1 4,21E-02 1,14E-09 1,17E+01 3,15E-07 AIEA Solid α 2,85 Sep-97 1010 U-232 1 3,20E-02 8,65E-10 1,31E-03 3,55E-11 AIEA Solid α Sep-97 1011 Y-80 1 6,17E+02 1,67E-05 0,00E+00 0,00E+00 CMI Solid γ 15,41 Sep-97 1012 H-3 20 < 7,40E+00 2,00E-07 2,77E-02 7,49E-10 AIEA Solid β 12,3 avr.-98 1013 C-14 20 < 3,70E+00 1,00E-07 3,25E+02 8,79E-06 AIEA Solid β 5715 avr.-98 1014 Source mixte Calibration Plate 68,9 Form No.: NLM-DIV-FORM-00-002 Rev: 03 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. 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No.: NLM-REP-14/197 Rev 2 Page No.: Page 70 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA A0 (Ci) At (KBq) At (Ci) Origin Nature Ray T (an) Da N.R RN Q A0 (KBq) Co-57 1 7,16E+02 1,94E-05 3,41E+00 9,22E-08 CMI Solid γ 0,745 juil-98 1015 Cd-109 1 3,46E+02 9,34E-06 3,69E+00 9,98E-08 CMI Solid γ 1,26 juil-98 1016 Mn-54 1 3,76E+02 1,02E-05 6,56E-03 1,77E-10 CMI Solid γ 0,854 juil-98 1017 Th-228 1 2,65E+03 7,17E-05 2,87E+01 7,74E-07 Canada Solid α 1,914 juin-99 1018 Ra-226 1 4,71E+03 1,27E-04 4,68E+03 1,27E-04 Canada Solid α 1600 juin-99 1019 Th-229 1 5,30E-02 1,43E-09 5,29E-02 1,43E-09 AIEA Solid α 7340 mai-00 1020 Am-241 3 7,40E+02 2,00E-05 7,28E+02 1,97E-05 AIEA Solid α 432,2 02-Jan 1021 Co-60 1 1,85E+06 5,00E-02 5,48E+05 1,48E-02 AIEA Solid γ 5,27 02-Oct 1022 Co-60 1 1,11E+06 3,00E-02 3,29E+05 8,89E-03 AIEA Solid γ 5,27 02-Oct 1023 Co-60 1 5,55E+05 1,50E-02 1,64E+05 4,44E-03 AIEA Solid γ 5,27 02-Oct 1024 Tl-204 1 3,70E+00 1,00E-07 3,35E+00 9,05E-08 ST Solid β 63 déc-02 1025 Sr-90 2 3,70E+00 1,00E-07 2,97E+00 8,04E-08 ST Solid β 28,6 03-Jan 1026 Co-57 1 3,70E+01 1,00E-06 3,62E+01 9,77E-07 ST Solid γ 271,79 03-Jan 1027 Na-22 1 3,70E+01 1,00E-06 3,36E+00 9,08E-08 ST Solid γ 2,6 03-Jan 1028 Co-60 2 3,70E+01 1,00E-06 1,11E+01 3,01E-07 ST Solid γ 5,27 03-Jan 1029 Cd-109 1 3,70E+01 1,00E-06 2,69E-01 7,27E-09 ST Solid γ 1,267 03-Jan 1030 Mn-54 1 3,70E+01 1,00E-06 2,49E-02 6,72E-10 ST Solid γ 0,854 03-Jan 1031 Br-133 Cs-137 1 3,70E+01 1,00E-06 2,08E+01 5,61E-07 ST Solid γ 10,8 03-Jan 1032 (Unknown) 1 3,70E+01 1,00E-06 3,01E+01 8,13E-07 ST Solid γ 30,2 03-Jan 1033 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. 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No.: NLM-REP-14/197 Rev 2 Page No.: Page 71 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA A0 (Ci) At (KBq) At (Ci) Origin Nature Ray T (an) Da N.R RN Q A0 (KBq) Ra-226 1 2,81E+02 7,59E-06 2,79E+02 7,55E-06 CMI Solid γ 1600 août-98 1034 Am-241 /Be 1 3,70E+07 1,00E+00 3,68E+07 9,96E-01 AIEA/ NESCA Solid η 432,2 déc-07 1035 Am-241 1 3,54E+01 9,55E-07 3,49E+01 9,43E-07 IPL Solid α 432,2 sept.-03 2001 Co-60 1 3,52E+00 9,51E-08 1,18E+00 3,18E-08 IPL Solid γ 5,27 sept.-03 2002 Cs-137 1 3,79E+01 1,02E-06 3,32E+01 8,96E-07 IPL Solid γ 30,2 sept.-03 2003 Zn-65 1 3,60E+01 9,73E-07 9,19E-02 2,48E-09 AREVA Solid X-γ 0,668 mars-06 2004 Fe-55 1 7,20E+01 1,95E-06 1,63E+01 4,40E-07 AREVA Solid X-γ 2,68 mars-06 2005 Cd-109 1 2,40E+01 6,49E-07 5,79E-02 1,56E-09 AREVA Solid X-γ 1,265 mars-06 2006 Am-241 1 3,70E+06 1,00E-01 3,62E+06 9,78E-02 AREVA Solid X-γ 432,2 janv.-01 2007 Fer-55 1 3,70E+05 1,00E-02 1,37E+04 3,70E-04 AREVA Solid X-γ 2,68 Avr 98 2008 Cd-109 1 3,70E+05 1,00E-02 6,42E+01 1,74E-06 AREVA Solid X-γ 1,265 Avr 99 2009 Am-241 1 29,6 8,00E-07 2,89E+01 7,80E-07 CEA Solid α 432,2 mars-96 2010 Co-60 1 4,41E+01 1,19E-06 5,52E+00 1,49E-07 CEA Solid γ 5,27 mars-96 2011 Cs-137 1 4,10E+01 1,11E-06 2,85E+01 7,71E-07 CEA Solid γ 30,2 mars-96 2012 Na-22 1 3,00E+01 8,11E-07 4,45E-01 1,20E-08 CEA Solid γ 2,602 mars-96 2013 Am-241 1 34,4 9,30E-07 3,35E+01 9,06E-07 CEA Solid γ 432,2 mars-96 2014 Co-60 1 43,2 1,17E-06 5,40E+00 1,46E-07 CEA Solid γ 5,27 mars-96 2015 Cs-137 1 45,6 1,23E-06 3,17E+01 8,58E-07 CEA Solid γ 30,2 mars-96 2016 Na-22 1 30,4 8,22E-07 4,51E-01 1,22E-08 CEA Solid γ 2,602 mars-96 2017 Ba-133 1 3,92E+01 1,06E-06 2,28E+01 6,17E-07 CEA Solid γ 10,7 sept.-03 2018 Cd-109 1 3,67E+02 9,92E-06 3,84E+00 1,04E-07 CEA Solid γ 1,267 sept.-03 2019 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. 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No.: NLM-REP-14/197 Rev 2 Page No.: Page 72 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA A0 (Ci) At (KBq) At (Ci) Origin Nature Ray T (an) Da N.R RN Q A0 (KBq) Eu-152 1 3,67E+00 9,92E-08 1,77E+00 4,77E-08 CEA Solid γ 13,51 sept.-03 2020 Pm-147 1 3,60E-01 9,74E-09 8,31E-03 2,25E-10 CEA Solid β 2.62 oct.-97 2021 Cl-36 1 3,84E-01 1,04E-08 3,84E-01 1,04E-08 CEA Solid β 3 E+5 oct.-97 2022 Sr-90 3 3,66E-01 9,89E-09 2,59E-01 6,99E-09 CEA Solid β 28,5 oct.-97 2023 Tc-99 1 3,23E-01 8,72E-09 3,23E-01 8,72E-09 CEA Solid β 2,1 E+5 oct.-97 2024 C-14 1 3,94E+00 1,07E-07 3,94E+00 1,06E-07 CEA Solid β 5730 oct.-97 2025 1 2,78E-03 7,51E-11 2,67E-03 7,23E-11 NIST Solid α 72 sept.-97 2026 γ 432,2 janv.-08 2027 source mixte (Am-241,U238, U-234, Pu239) source mixte (Am241,Mn54) MB 1 3,70E+00 1,00E-07 3,68E+00 9,94E-08 ANALYTICS (0,5 L) This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. 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No.: NLM-REP-14/197 Rev 2 Page No.: Page 73 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA RN Q A0 (KBq) A0 (Ci) At (KBq) At (Ci) Origin source mixte (Am241,Mn54) Nature Ray T (an) Da N.R γ 432,2 janv.-08 2028 mai-95 2029 MB 1 3,70E+00 1,00E-07 3,60E+00 9,74E-08 ANALYTICS (1 L) Tc-99 1 1,91E-04 5,16E-12 0,00E+00 0,00E+00 ANALYTICS Solid β 2,111 E+5 Cs-137 1 3,26E+01 8,80E-07 2,24E+01 6,06E-07 ANALYTICS Solid β 30,2 sept.-95 2030 Th-230 1 1,64E-04 4,43E-12 1,64E-04 4,43E-12 ANALYTICS Solid β 7,703 E+4 sept.-95 2031 Na-22 1 2,63E+00 7,11E-08 7,27E-02 1,96E-09 CMI Solid γ 2,6 juil.-98 2032 Ra-226 1 3,16E+00 8,55E-08 6,08E-14 1,64E-21 CMI Solid γ 1600 juil.-98 2033 Cs-137 1 2,94E+00 7,93E-08 4,75E-05 1,28E-12 CMI Solid γ 30,2 juil.-98 2034 Am-241 1 8,91E+00 2,41E-07 8,72E+00 2,36E-07 CMI Solid γ 432,2 juil.-98 2035 Co-60 1 3,51E+00 9,48E-08 5,97E-01 1,61E-08 CMI Solid γ 5,27 juil.-98 2036 Ra-226 1 2,96E+00 7,99E-08 2,94E+00 7,94E-08 CMI Solid γ 1600 sept.-97 2037 Cd-109 1 1,76E+01 4,75E-07 1,13E-02 3,06E-10 CMI Solid γ 1,267 juil.-98 2038 Sr-85 1 3,86E+00 1,04E-07 3,52E+00 9,50E-08 CMI Solid γ 64,78 juil.-98 2039 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. 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No.: NLM-REP-14/197 Rev 2 Page No.: Page 74 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA A0 (Ci) At (KBq) At (Ci) Origin Nature Ray T (an) Da N.R RN Q A0 (KBq) source mixte gamma + Am-241 1 9,15E+01 2,47E-06 9,03E+01 2,44E-06 CMI Solid γ 432,2 avr.-03 2040 Ba-133 1 4,88E+00 1,32E-07 2,78E+00 7,51E-08 CMI Solid γ 10,7 avr.-03 2041 Eu-152 1 5,11E+00 1,38E-07 3,27E+00 8,83E-08 CMI Solid γ 13,51 avr.-03 2042 Ra-226 1 5,18E+00 1,40E-07 5,17E+00 1,40E-07 CMI Solid γ 1600 avr.-03 2043 Am-241 1 5,28E-01 1,43E-08 5,24E-01 1,42E-08 E&Z Solid γ 432,2 Mars.-07 2044 Sr-90/ Y-90 1 4,99E-01 1,35E-08 4,49E-01 1,21E-08 E&Z Solid γ 28,5 févr.-07 2045 Sr-85 1 1,608 4,35E-08 1,51E+00 4,08E-08 AREVA Solid X 64,78 Mars.-06 2046 Co-57 1 40,2 1,09E-06 1,65E-05 4,47E-13 CEA Solid γ 0,745 Mars.-96 2047 Cr-51 1 60,6 1,64E-06 2,25E-62 6,09E-70 CEA Solid γ 0,075 Mars.-96 2048 Mn-54 1 35,9 9,70E-07 9,65E-05 2,61E-12 CEA Solid γ 0,854 Mars.-96 2049 Sr-85 1 41,7 1,13E-06 3,52E+01 9,52E-07 CEA Solid γ 64,78 Mars.-96 2050 Y-88 1 34,7 9,38E-07 2,01E-15 5,44E-23 CEA Solid γ 0,293 Mars.-96 2051 Co-57 1 57,8 1,56E-06 2,38E-05 6,43E-13 CEA Solid γ 0,745 Mars.-96 2052 Cr-51 1 58,4 1,58E-06 2,17E-62 5,87E-70 CEA Solid γ 0,075 Mars.-96 2053 Mn-54 1 42,9 1,16E-06 1,15E-04 3,12E-12 CEA Solid γ 0,854 Mars.-96 2054 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: NLM-REP-14/197 Rev 2 Page No.: Page 75 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA A0 (Ci) At (KBq) At (Ci) Origin Nature Ray T (an) Da N.R RN Q A0 (KBq) Sr-85 1 45,1 1,22E-06 3,81E+01 1,03E-06 CEA Solid γ 64,78 Mars.-96 2055 Y-88 1 38,2 1,03E-06 1,05E-07 2,83E-15 CEA Solid γ 0,293 Mars.-96 2056 Mn-54 1 2,58 7,00E-08 4,75E-05 1,28E-12 CEA Solid γ 0,854 Juillet.-98 2057 Y-88 1 4,533 1,23E-07 6,08E-14 1,64E-21 CEA Solid γ 0,293 juillet.-98 2058 Co-57 1 0,783 2,12E-08 1,27E-06 3,45E-14 CEA Solid γ 0,745 juillet.-98 2059 Mixed Gamma 1 Sans activité - - - CEA Solid γ - juillet.-98 2060 Cs-137 1 9,17E+03 2,48E-04 8,24E+03 2,23E-04 AIEA Solid γ 30,2 sept.-05 3001 I-131 1 1.11E+06 3,00E-02 2,66E-59 7,19E-67 Pharmacie centrale Solid γ 0,022 Avr.07 3002 This document is the property of NECSA and shall not be used, reproduced, transmitted or disclosed without prior written permission. Doc. No.: Page No.: NLM-REP-14/197 Rev 1 Page 76 of 76 DRAFT SAFETY CASE FOR THE MANAGEMENT OF DISUSED SEALED RADIOACTIVE SOURCES IN TUNISIA 20.0 APPENDIX E: SAFRAN ASSESSMENT Form No.: NLM-DIV-FORM-00-002 Rev: 03