Practical challenges in implementing the BSS requirements (Regulatory Control of NORM): MALAYSIA. Dr. TENG IYU LIN LICENSING DIVISION

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1 Practical challenges in implementing the BSS requirements (Regulatory Control of NORM): MALAYSIA Dr. TENG IYU LIN LICENSING DIVISION Atomic Energy Licensing Board Ministry of Science, Technology and Innovation (MOSTI) MALAYSIA Ensuring Safety, Security & Safeguarding Peaceful Nuclear Activities

2 CONTENT AELB, ACT & REGULATIONS NORM IN MALAYSIA ACT 304 LICENSING REGULATIONS, 1986 BASIC SAFETY RADIATION PROTECTION, 2010 RADIOACTIVE WASTE MANAGEMENT, 2011 EXEMPTION ORDER LOW LEVEL RADIOACTIVE MATERIAL & SMALL AMANG FACTORY CODE OF PRACTICE - OIL & GAS REGULATORY REQUIREMENTS BASED ON GSR PART 3 CHALLENGES 2

3 AELB, ACT & REGULATIONS Atomic Energy Licensing Act 1984 (Act 304) To provide for the regulation and control of atomic energy; For the establishment of standards on liability for nuclear damage; and For matters connected therewith or related thereto. Minister of Science, Technology & Innovation The Board (5 Members) Executive Secretary Ministry of Science, Technology & Innovation (General Secretary) Director General AELB Department Regulatory Body: Atomic Energy Licensing Board (AELB) was establish under Section 3 of the Act. 304 Ensuring safety, security and safeguarding peaceful Nuclear Activities Standing Safety Committee Substanding Safety Committee Nuclear Installation Division Technical Support Division Administrative Services Division Policy, Code & Standard Division Licensing Division Enforcement Division 3

4 Hierarchy of Legal System Atomic Energy Licensing Act (1984 ) (ACT 304) Regulations Act: provides the basic law concerning the development and utilization of atomic energy and safety regulations. Regulations: provides more detailed provisions entrusted by the Act. Section 68 Act 304 Orders and Conditions of License Guidelines, Codes and Standards Provides additional requirement which not stated in the regulations or special matters related to provisions entrusted by the Act Orders: Sec 69 Act 304 Licence conditions: Section 17 Act 304 Provides guides, codes and standards to comply with and achieve goal impose in regulations 4

5 ATOMIC ENERGY LICENSING ACT 1984 (ACT 304) Scope of the Act 304 To control any : radioactive materials, nuclear materials, prescribed substances, or irradiating apparatus in medical and non-medical application.

6 ATOMIC ENERGY ACTIVITIES IN MALAYSIA a. NON MEDICAL ACTIVITIES Gamma sterilization Non Destructive Testing Gauging Oil Logging NORM/ TENORM Research Archeology Others b. MEDICAL ACTIVITIES 6

7 NORM IN MALAYSIA NORM vs TENORM: a) Milling of minerals containing naturally occurring radionuclides: RAW MATERIAL PROCESS PRODUCT + BY PRODUCT (NORM) (TENORM) b) Tin mining/ smelting activities TIN MINING: TIN CONCENTRATE + TIN TAILING TIN SMELTING: TIN INGOT + TIN SLAG c) Oil and gas industries OIL SCALE AND SLUDGE 7

8 NORM RESIDUES/ WASTES GYPSUM IRON OXIDE OIL SLUDGE/ SCALE TIN TAILIN (AMANG) TIN SLAG

9 RADIATION PROTECTION REGULATIONS (LICENSING) 1986 Explain the procedure and information needed to obtain, renew and amend the license from the Board.

10 REG 3:CLASSIFICATION OF LICENCE CLASS A CLASS B CLASS C CLASS D CLASS E CLASS F CLASS G CLASS H RADIOACTIVE MATERIAL NUCLEAR MATERIAL IRRADIATING APPARATUS TRANSPORTATION IMPORT & EXPORT NUCLEAR INSTALLATION DISPOSAL/STORAGE RADIOACTIVE MATERIAL BEFORE DISPOSE OTHERS ACTIVITY -Manufacture -Trade in -Produce -Process -Purchase -Own -Possess -Transfer -Handle -Sell -Store -Import -Export ACTIVITY -Same as Class A ACTIVITY ACTIVITY ACTIVITY ACTIVITY ACTIVITY ACTIVITY -Purchase -Sell -Trade in -Transfer -Import -Export -Possess -Own -Use -Store -Handle -Transport -Import -Export -Same as Class A -Dispose -Store -Maintenance -Leak test

11 ATOMIC ENERGY LICENSING (BASIC SAFETY RADIATION PROTECTION) 2010 Introduction Atomic Energy Licensing (Basic Safety Radiation Protection) Regulations 2010 [P.U.(A) 46] replaced the [Radiation Protection (Basic Safety Standards) Regulations, 1988] Come into operation on 15th February 2010; and Describe the principles of radiation protection and safety such as, system of dose limitation (justification, optimization), medical exposure, operational radiation protection and role of licensee and radiation worker. 11

12 ATOMIC ENERGY LICENSING (RADIOACTIVE WASTE MANAGEMENT) REGULATIONS, COMMENCEMENT: REGULATIONS COME INTO OPERATION ON 16 AUGUST APPLICATION: SHALL APPLY TO ALL ASPECTS OF RADIOACTIVE WASTE AND WASTE MANAGEMENT ARISING FROM MEDICAL, INDUSTRY, RESEARCH & ANY OTHER APPLICATION WHICH MAY BE SPECIFIED BY THE BOARD. 3. INTERPRETATION: CLEARANCE LEVEL THE VALUES ESTABLISHED BY THE BOARD AND EXPRESSED IN TERMS OF ACTIVITY CONCENTRATION OR TOTAL ACTIVITY, AT OR BELOW WHICH THE SOURCE OF RADIATION MAY BE RELEASED FROM CONTROL (2nd SCHEDULE)

13 eg. SECOND SCHEDULE 13

14 EXEMPTION 1. ATOMIC ENERGY LICENSING (EXEMPTION) (LOW LEVEL RADIOACTIVE MATERIAL) CALIBRATION SOURCE, CHECK SOURCE, STANDARD SOURCE, REFERENCE SOURCE 2. ATOMIC ENERGY LICENSING (EXEMPTION) (SMALL AMANG FACTORY) Small Amang Factory means any factory processing amang which may cause exposure of ionizing radiation to the whole body of a worker not exceeding 50 milisieverts (msv) per annum.

15 CODE OF PRACTICE ON RADIATION PROTECTION RELATING TO TECHNICALLY ENHANCED NATURALLY OCCURRING RADIOACTIVE MATERIAL (TENORM) IN OIL AND GAS FACILITIES Parameter External dose rate Contaminated materials: External dose rate at 5 cm from surface Waste categorization based on TAC: Total Activity Concentration (TAC) Waste disposal: - Dose to critical group Control Limit 0.5 usv/h 0.5 usv/h 3.0 Bq/g (inclusive b/ground) 0.3 msv/y 15

16 CODE OF PRACTICE ON RADIATION PROTECTION RELATING TO TECHNICALLY ENHANCED NATURALLY OCCURRING RADIOACTIVE MATERIAL (TENORM) IN OIL AND GAS FACILITIES 16

17 REGULATORY REQUIREMENTS IAEA: GSR PART 3 1. INTRODUCTION 2. GENERAL REQUIREMENTS FOR PRORECTION AND SAFETY 3. PLANNED ESPOSURE SITUATIONS 4. EMERGENCY EXPOSURE SITUATIONS 5. EXISTING EXPOSURE SITUATIONS AELB: Atomic Energy Licensing (Basic Safety Radiation Protection) Regulations 2010 [P.U.(A) 46] 17

18 1. INTRODUCTION Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards (GSR Part 3) establish requirements for the protection of people and the environment from harmful effects of ionizing radiation and for the safety of radiation sources which apply to the 3 categories of exposure: a. Occupational exposure b. Public exposure; and c. Medical exposure 18

19 2. GENERAL REQUIREMENTS FOR PROTECTION AND SAFETY Application of all principles of radiation protection for all exposure situations Establish and maintain an appropriate and effective legal and regulatory framework for protection and safety Training and recognition of competence workers in protection and safety Graded approach to the implementation of the system of protection and safety Protection and safety elements of the management system Safety culture/ human factors 19

20 REGULATORY CONTROL ACT 304 GSR Part 3 Dose limits : 8(1) Workers 20 msv/y 9(1) Public 1 msv/y Competence workers RPO/ RPA Training Specified in Radiation Protection Program Dose limits : Workers 20 msv/y Public 1 msv/y Training and recognition of competence workers in protection and safety 20

21 REGULATORY CONTROL Act 304 GSR Part 3 Authorization: Licensing (Class A-milling; Class G store/ dispose of radioactive wastes; Class H- D&D, consultation) Enforcement: inspection, environmental monitoring & sampling etc Graded approach to the implementation of the system of protection and safety Registration: SEM, Lightning Arrester Release from Regulatory Control: RADIOACTIVE WASTE (NORM): U/Th < 1 Bq/g OIL SLUDGE: TAC < 3.0 Bq/g 21

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24 ENVIRONMENTAL MONITORING Soil Monitoring methods ERMS Water In-Situ Air TLD

25 3. PLANNED EXPOSURE SITUATIONS SCOPE: The mining and processing of raw materials that involve exposure due to radioactive material; Eg: rare earth extraction plants Exposure due to natural sources (in general considered an existing exposure situation), the relevant requirements for planned exposure situations apply to: Exposure due to material where the activity concentration in the material of any radionuclide in the uranium or thorium decay chains is greater than 1 Bq/g or the activity concentration of K-40 is greater than 10 Bq/g. Eg: ex-mining activities (Amang plants) 25

26 3. PLANNED EXPOSURE SITUATIONS GRADED APPROACH - Licensing: Processing of minerals containing NORM - Exemption & Registration: Amang plant NOTIFICATION AND AUTHORIZATION - Section 12(1)(b) Act Radiation Protection (Licensing) Regulations 1986 Class A (milling) licence Licence conditions (import/ export/store/process etc) EXEMPTION AND CLEARANCE - eg. Small Amang Plant Exemption Order Clearance levels Schedule 2 (Waste Regulations, 2011) 26

27 EXPOSURE DUE TO NATURAL SOURCES IS IN GENERAL CONSIDERED AN EXISTING EXPOSURE SITUATION AND IS SUBJECT TO THE REQUIREMENTS STATED IN SECTION 5. TABLE 1-3 LEVEL FOR CLEARANCE OF MATERIAL: ACTIVITY CONCENTRATIONS OF RADIONUCLIDES OF NAUTRAL ORIGIN Radionuclide Activity Concentration (Bq/g) K Each radionuclides in the uranium and thorium decay chains 1 27

28 3. AUTHORIZATION: REQUIREMENTS DOSE LIMITS - Workers: 20 msv/yr - Public; 1 msv/yr SAFETY ASSESSMENT - Shall be conducted at different stages including the stages of siting, design, manufacture, construction, assembly, commissioning, operation, maintenance and decommissioning. MONITORING FOR VERIFICATION OF COMPLIANCE - Review and approve monitoring & measurements program - Emergency Preparedness and Response - Maintain inventory records - Occupational exposure compliance with dose limits - Monitoring of the workplace - Workers health surveillance - Training - Classifications of working areas 28

29 4. EMERGENCY EXPOSURE SITUATIONS Emergency management system is established and maintained for the purposes of emergency response to protect human life, health and the environment in the event of a nuclear or radiation emergency. Technical Guide: - LEM/TEK/66: for the preparation of Emergency Plan and Drill - Training & Drill once/year (internal) 29

30 National Radiological Emergency Response Drill 30

31 5. EXISTING EXPOSURE SITUATIONS Existing exposure situations apply to: i. Contamination of areas by residual radioactive material past activities that never subject to regulatory control, eg. Tin mining ii. Exposure due to natural sources, in which the activity concentration of no radionuclide in either the uranium or thorium decay chains exceeds 1 Bq/g or the activity concentration of K-40 does not exceed 10 Bq/g The regulatory body shall ensure: Remediation of areas with residual radioactive materials - Landfilling/ reclamation Establish and implement an action plan for controlling public exposure due to radon indoors - ventilation Establish and enforce requirements for the protection of workers - environmental monitoring - PPE provided to the workers 31

32 CHALLENGES 1. Existing exposure situation: Contamination of areas by residual radioactive Material (tin mining activities); which radionuclide in either the uranium or thorium decay chains exceeds 1 Bq/g or the activity concentration of K-40 exceed 10 Bq/g [REMEDIATION] 2. Processing of raw materials that involve exposure due to material where the activity concentration in the material of any radionuclide in the uranium or thorium decay chains is greater than 1 Bq/g or the activity concentration of K-40 is greater than 10 Bq/g. [AUTHORIZATION] 3. Public acceptance After the Fukushima accident, the decision making process in controlling and supervising atomic energy activities, especially related to mineral processing and disposal of radioactive waste containing NORM had been reviewed. [PUBLIC ACCEPTANCE] 4. Competence authority - Increase public confidence: 3S (SAFETY, SECURITY & SAFEGUARD) 32

33 1. EXISTING EXPOSURE SITUATION Existing exposure situation: Contamination of areas by residual radioactive Material (tin mining activities); which radionuclide in either the uranium or thorium decay chains exceeds 1 Bq/g or the activity concentration of K-40 exceed 10 Bq/g Isodose mapping throughout the country (environmental monitoring and sampling etc) Remediation of ex-mining areas (landfilling/ reclamation) Development of ex-mining areas (Future plan) - Ventilation - PPE to workers 33

34 MONITORING EQUIPMENTS AND PPE

35 2. PROCESSING OF RAW MATERIALS Processing of raw materials that involve exposure due to material where the activity concentration in the material of any radionuclide in the uranium or thorium decay chains is greater than 1 Bq/g or the activity concentration of K-40 is greater than 10 Bq/g. Authorization: Licensing Licence conditions: Import/ exports/ storage/ processing Radioactive waste management -waste minimization (Reduce, Reuse. Recycle) - disposal facility 35

36 3. PUBLIC ACCEPTANCE Indirectly, Fukushima accident also had influenced the decision making process in controlling the atomic energy activities in Malaysia. This also had given big impact on the level of thrust to the regulator in controlling and supervising atomic energy activities, especially related to mineral processing and disposal of radioactive waste containing NORM. Thus, AELB have increased its public engagement activities and make it a compulsory to all applicants for mineral containing NORM processing and radioactive waste disposal activities. 36

37 Public Acceptance Activities Outreach/ Awareness program - Outreach program to the politicians, other governmental officers, industries, school and universities students - Awareness program & Public communication - Address Public Concern, Ensure Safety & Health Of The Public, Workers And The Environment Public Engagement - Media briefing - Presentation - FAQ (online)

38 4. COMTEPENCE AUTHORITY: TO ENHANCE PUBLIC CONFIDENCE NUCLEAR SECURITY & PHYSICAL PROTECTION: RADIOACTIVE MATERIAL CATEGORY 1-3: SECURITY PLAN THREAT ASSESSMENT NATIONAL RADIOACTIVE AND NUCLEAR DETECTION SYSTEM (PORTAL MONITOR): To prevent illicit trafficking/illegal movement of radioactive and nuclear material ENVIRONMENTAL RADIATION MONITORING SYSTEM (ERMS): A detection of early warning sign of trans-boundary radioactivity on the environmental in case of any radiation or nuclear contamination 38

39 NUCLEAR SECURITY & PHYSICAL PROTECTION National Emergency Response Centre INFRASTRUCTURE FOR MONITORING OF 3 S : SAFETY, SECURITY AND SAFEGUARDS - Incident - Accident - Sabotage - Illicit trafficking - Misused Environmental radiation monitoring system Illicit trafficking & border control 39

40 Environmental Radiation Monitoring System ERMS Malaysia have installed ten (10) units of Environmental Radiation Monitoring System (ERMS) throughout the country that gives a detection of early warning sign of trans-boundary radioactivity on the environmental in case of any radiation or nuclear contamination Data from all site are transmitted and monitored at AELB control centre.

41 Thank you