DR JOHN LOY CHEF EXECUTIVE OFFICER  ARPANSA, PO Box 6 5 5 ,  Mranda NSW 1490

SUMMARY

The International Atomic Energy Agency (IAEA) has data on over 670 research reactors in the world. Fewer  than half of them are operational and a significant number are in a shutdown but not decommissioned state. The  International Nuclear Safety Advisory Group (INSAG) has expressed concerns about the safety of many  research reactors and this has resulted in a process to draw up an international Code of Conduct on the Safety of  Research Reactors, The IAEA is also reviewing its safety standards applying to research reactors.

On the home front, regulation of the construction of the Replacement Research Reactor continues. During the  construction phase, regulation has centred around the consideration of Requests for Approval (RFA) for the  manufacture and installation of systems, structures and components important for safety. Quality control of  construction of systems, structures and components is the central issue. The process for regulation of  commissioning is under consideration.

1. INTRODUCTION

The Research Reactor Database maintained by the  International Atomic Energy Agency (IAEA) has  records on a total of 674 civilian research reactors  that have ever been constructed in the world. It  reports that 272 of the research reactors are still  operational, 216 are shutdown and 168 are  decommissioned.

The term ‘research reactor’ in this database covers  essentially every reactor that is or was not being  used routinely for generation of electrical power. It  ranges from experimental fast breeders producing

several hundreds of MW through to 1 kW critical  assemblies.

2. CODE OF CONDUCT ON THE SAFETY OF  RESEARCH REACTORÂ§

The International Nuclear Safety Advisory Group  (INSAG), which is a committee of the great and  good in nuclear safety, wrote to the Director General  of the IAEA in November 1998 about the safety of  research reactors. It noted that there were a  significant number of research reactors in a state of  shutdown (but without definitive plans for the  future); there were major issues related to the ageing  of research reactors; that they are not covered by the  present safety conventions and that participation by  member states in relevant Agency programs was  rather low; many have large stocks of spent fuel,

much of which contains HEU; there are issues of

operating safety of new high flux reactors, with  some developing countries building their first  research reactor whilst lacking nuclear

infrastructure; and that regulatory supervision has  been found to be inadequate or even non-existent in  some countries. INSAG recommended that the  Agency assess its projects affecting research

reactors, such as safety review missions, within a  structured approach with clear priorities  commensurate with safety relevance. In particular,  INSAG recommended that high priority be given to

reviewing the condition of shutdown reactors,

In April 2000, INSAG (now appointed for its fifth  term) wrote again to the Director General. It stated  that ‘while fully endorsing the concerns expressed  by the previous INSAG, it must regretfully  recognise that

-------- the problem remains very

serious. ’ The November 2000 letter rehearsed the  issues raised in the earlier correspondence and,  while noting the efibrts of the Secretariat, stated that  ‘the Member States may as yet have realized neither  the urgency of the issue nor the dimension of the  problem. ’ INSAG suggested the development of a  Protocol to the Convention on Nuclear Safety or

some similar legal instrument as a way of  establishing a better, international safety framework  for these reactors. It recognised that this would take  some time to develop and, in the meantime,

recommended urgent action in two areas: proper  dccornmissioning of the reactors that are shutdown,  but not decommissioned; and a thorough review of  the safety of the older research reactors not undcr the

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control of an independent national regulatory  authority.

Taking a step back, the creation of a framework of  international law dealing with nuclear safety had  begun following the Chernobyl accident in 1986.  That disaster had illustrated that the matter of

nuclear safety was not simply a national one. The  first Conventions that came into effect were those  relating to an obligation for countries to notify the  occurrence of a nuclear or radiological emergency

and for emergency assistance. These were followed  the Convention on Nuclear Safety, which deals with  nuclear power plant. This Convention broadly sets  out the 'golden rules' that a country should adopt for  the safety of nuclear power. Its most important  provisions are those that require countries to report

on their safety regime against the provisions of the  Convention and for these reports to be peer-  reviewed in a three yearly meeting.

A similar approach has been taken in regard to the  safety of radioactive waste facilities through the  clumsily titled Joint Convention on the Safety of  Spent Fuel Management and the Safety of  Radioactive Waste Management.

In considering the letters from INSAG, there was not  a great deal of support amongst countries for a new  Convention to cover research reactors, either a fully  new Convention or by some extension of the  Convehion on Nuclear Safety (which, in any case  allows for countries with research reactors to ratify  the Convention and apply it to their research  reactors. Australia is a member of the Convention).  The Joint Convention also deals with facilities for

management of waste and spent he1 form research  reactors.

And  so the notion emerged of creating a Code of  Conduct on the safety of research reactors. While  such a Code would be an international instrument, it  would be non-binding on countries.

A similar approach has been taken to the safety and  security of radioactive sources where a (newly  revised) Code of Conduct was adopted by the Board  of Governors of the IAEA in September this year.

Discussions on the drafting of a research reactor  Code of Conduct began in May 2002 and with luck  it may be adopted during 2004.

The draft Code of Conduct endeavours to set out the  golden rules for the safety of rescarch reactors. In  doing so, it directs attention not only to the  responsibilities of the State, but to those of the  regulatory body and the operator - Conventions, by  their nature are limited to the State. It explicitly  deals with the safety approach to a slate of extended

shutdown. Given the very broad range of research  reactors, it ernphasises the need for a graded  approach to safety, based upon assessment of  hazard.

By and large, these matters are not controversial.  The difficulty has been in discerning what it means  to have a non-binding instrument and then calling  upon States to implement it. There are also issues  about the import and export of research reactors and

the linking of the Code to technical assistance  through the KEA.  3. IAEA SAF'ETY STANDARDS

For research reactor regulation and safety, the IAEA  first published in 1992 two standards on design and  operation and in 1994 two safety guides on safety  assessment and S A R ,  and on utilisation and  modification. Since then a number of documents

have been prepared but they failed to be published  because of a variety of reasons best known to the  Agency itself, but probably involving limited  resources for this area and elements of international  bureaucratic inertia and its attendant international

consensus seeking processes.

In 1996 it was recommended that the Agency revise  and merge the two safety standards to produce a  single updated standard to ensure consistency and  compatibility with the other IAEA Safety Standards  and to incorporate new developments in the safety  philosophy such as management and verification of

safety. The resulting draft document, entitled  "Safety Requirements of Research Reactors" (DS  272) has been subject to a long gestation. It is now  reaching the final approval stages, together with  three safely guides on "commissioning",

"maintenance, periodic testing and inspection", and  "operational limits and conditions and operating  procedures" (DS 259, DS 260 and DS 261,  respectively). It is expected that the Agency will

move to formally publish these Standards next year.  Together with the Agency guidance on generic  safety issues, these Standards will form an effective  suite of higher level international guidance for the

regulation of research reactors.

Because of their utilisation and design, research  reactors tend to have fewer automatic controls than  power reactors and are dependent on personnel  actions. Many safety significant actions and  processes are carried out by facility personnel and  controlled by administrative processes and  procedures. Because of these factors, the topic of  the operating organisation and the rccruitment,  training and qualification of personnel for research

reactors is being addressed in another safety guide  currently close to completion. Also a draft Guide on  Operational Radiation Protection at Research

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Reactors is at an advanced stage of development  with this document providing specific guidance for  research reactor operational radiation protection that  is not otherwise provided in other, more wide-

ranging, radiation protection guides. This  operational radiation protection Guide is intended to  put in proper context the considerations of  radiological hazard according to research reactor  type, power, radionuclide inventory, transient

characteristics, and irradiation and experimental  facilities.

Other recent or planned international activities under  the auspices of the IAEA include review and  preparation of material covering “Safety analysis of  research reactors”, “Safety of new and existing

research reactors in relation to external events”,  “Source term derivation and radiological  consequence analysis of research reactor accidents”  and workshops on thermal hydraulic validations for

research reactors, and on accident fission product  releases and dose estimates.

ARPANSA has used the IAEA research reactor  Standards in draft form, and will continue to use  them when formally published to guide its safety  assessment and regulation of both HIFAR and the

RRR, supplemented of course by any necessary  detailed or specific regulatory acceptance criteria or  requirements determined by our particular context.  This is the basis for ARPANSA’s regulation of

Australia’s research reactors and as such represents a  part of the application of international best practice  in the field of research reactor safety and regulation.

4. REGULATION OF THE REPLACEMENT  RESEARCH REACTOR

Regulation 54 of the ARPANS Regulations 1999  imposes a licence condition on facility licences to  the effect that the licence holder must not construct  an item that is important for safety and that is  identified in a safety analysis report unless the CEO  has given approval to construct the item.

In issuing the licence to ANSTO for the construction  of the RRR, I imposed licence condition 4.6, which  effectively expanded on the condition imposed by  Regulation 54 by setting out the process for  obtaining approvals for items important for safety.

In seeking my approval for the construction of items  important for safety, ANSTO puts forward a  Request for Approval @FA) that sets out the  information sought in licence condition 4.6. Since I

issued the construction licence in April 2002,  ARPANSA staff have completed assessments of  more than 80 WAS.

The information sought under licence condition 4.6  and provided in the relevant RFA is first:

That the detuiled design of the items has been  completed in accordance with the design description  and intentions in the Application; and  reviewed, verified and accepted by the Licence  Holder.

This condition aims to ensure that the detailed  design of the item is consistent with the description  in the application to construct - that is, that it is  consistent with the basis on which the licence to

construct was issued. It also is a check as to whether  ANSTO has taken control of the design put forward  by INVAP. In assessing the RFA against these  criteria, ARPANSA staff overview drawings and

technical specifications and ANSTO’s own review  of these, particularly to see if there are major  unresolved design issues. The RFA describes  whether the design fully meets the description of the  item set out in the PSAR. Where there are  differences and these are important for safety, there

needs to be a justification for the changed approach.

ARPANSA staff examine whether ANSTO has  reviewed, verified and accepted the design,  focussing on how matters raised by ANSTO with the  designer have been dealt with by

the designers.

Turning to construction, the licence condition is as  follows:

That construction of the item will be:  in accordance with the detailed design;  under a certi$ed quality assurance program;  in accordance with a program that has been  documented, reviewed and approved by the Licence  Holder; and

under a construction schedule that is made available  to the  CEO ofARPANSA.

This condition first allows ARPANSA to be assured  that the detailed design is detailed, complete and  sufficient for manufacture and installation. In  assessing the RFA against these criteria, ARPANSA

staff direct attention to the inspection and test plans  that are proposed and to the existence and  certification of a quality system applying to the  manufacturer of the item.

In terms of control over the construction of the item,  this condition relies upon there being a certified  quality assurance program applying to the  manufacturer of the item.

In addition, ANSTO must demonstrate that it has  taken into account recommendations set out in the  Regulatory Assessment Report on the construction  licence application that apply to the itcm in question.

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HA will list the relevant recommendations and  provide a response, which is assessed by ARPANSA  staff.

Once I (or the authorised ARPANSA offker) have  considered an RFA, I then make a decision whether  or not to approve construction of a particular item,  The terms of the approval are very important as they  iilstruct the licence holder as to the parameter of that  approval and whether the approval is the subject of \  conditions (either contained within the approval or  imposed as additional licence conditions). An  example of the former is an approval which

incorporates within it the requirement that ANSTO  observe certain “hold points” in a construction  process; an example of the latter is the requirement  that in constructing a reactor vessel that ANSTO  undertake 100% radiography of certain types of  welds.

As most will be aware, three particular regulatory  issues have emerged during the construction - the  first being the discovery of faulting on the reactor  site; the second being a breach of licence condition  by INVAP in authorising the construction of cut-  outs in the pool liner base that had been explicitly  excluded from my approval; the third being the  inside-out rolling of the pool liner plates resulting in  misplaced penetratiods.

I will not repeat here the actions that ARPANSA  took - these are set out in detail on the ARPANSA  website and in my reports to Parliament. Suffice it to  say that ARPANSA’s regulatory approach has been  to undertake a very public process of detailed

inquiry into these matters and to publish detailed  reports dealing with them.

On the horizon is the next set of regulatory  challenges as we think through how to deal with the  commissioning process and, all being well, the  transition to operating the Replacement Research  Reactor. The experience of INVAP’s reactor in  Egypt and the AECL’s MAPLE reactors in Canada

suggest that there is the potential for plenty of  possibilities that we may have to face up to.

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