Provisions of Code of Conduct for Research reactor on Legal and Governmental Infrastructure and Role of Regulatory Body - Status of Bangladesh

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1 1 Provisions of Code of Conduct for Research reactor on Legal and Governmental Infrastructure and Role of Regulatory Body - Status of Bangladesh Meherun Nahar Bangladesh Atomic Energy Regulatory Authority Regional workshop on application of the code of conduct on the safety of research reactors ; Core Management and Safety of Experiment September, Yogyakarta, Indonesia

2 Content 2 Bangladesh Atomic Energy Regulatory Authority (BAERA) Governmental and Legal Framework for Safety BAERA role s Regulatory Framework 3 MW TRIGA Mark-II Research Reactor Licensing of Research Reactor Conclusion

3 3 Ministry of Science and Technology BAEC BCSIR NMST NIB BANSDOC BSMR BAERA BAEC Bangladesh atomic Energy Commission BCSIR Bangladesh Council of Scientific Research NMST National Museum of Science & Technology NIB National Institute of Biotechnology BANSDOC Bangladesh National Scientific and Technical Documentation Centre BSMR Bangabandhu Sheikh Mujibur Rahman Novo Theatre BAERA Bangladesh Atomic Energy Regulatory Authority

4 BAEC Organizational Structure 4 CHAIRMAN Member (Physical Science) Member (Engineering) Member (Planning & Dev.) Member (Bio-Science) Atomic Energy Center RTML BSMEC AED FAD QS CELL INMU 13 CNMU IAD SID TD NPED NSRCD NSSD PSD Physical Science Division SID Scientific Information Division IFRB Institute of Food and Radiation Biology ED Engineering Division TD Training Division IE Institute of Electronics PDD Planning and development Division NPED Nuclear Power and Energy Division ICS Institute of Computer Science BSD Bio-Science Division NSRCD Nuclear Safety and Radiation Control Division ROMU Reactor Operation and Monitoring Unit AEC Atomic Energy Center NSSD Nuclear Safeguards and Security Division EI Energy Institute RTML Radioactivity Testing and Monitoring Laboratory AED Administration and Establishment Division NMU Nuclear Minerals Unit BSMEC Beach Sand Minerals Exploitation Center FAD Finance and Accounts Division CEF Central Engineering Facilities INMU Institute of Nuclear Medicine and Ultrasound QS Cell Quality System Cell SIU Scientific Information Unit CNMU Center for Nuclear Medicine and Ultrasound AERE Atomic Energy Research Establishment TBBRU Tissue Banking and Biomaterial Research Unit IAD International Affairs Division INST Institute of Nuclear Science and Technology IRPT Institute of Radiation and Polymer Technology

5 Proposed Organgram for BAERA Ministry of Science and Technology Total Proposed manpower-360 Secretary Bangladesh Atomic Energy Regulatory Authority (Chairman) Finance Advisor Member (Nuclear Safety) Member (Radiation Safety) Member (Technical) Member (Planning & Development Nuclear Facility Authorization & Inspection Division Radiological Facility Authorization & Inspection Division Regulatory Affairs Division International Cooperation and public relation Division Nuclear Safety & Security Division Emergency, planning, Preparedness and Response Division Technical Services Division Human Resources Development Division Safety Evaluation & Risk Assessment Division Transport & Waste Safety Division Legal & Enforcement Division

6 6 Governmental and Legal Framework for Safety Legal Instrument Bangladesh Atomic Energy Regulatory Act-2012(Act no 19 of 2012) To regulate the peaceful use of atomic energy Nuclear Safety and Radiation Control (NSRC) Rules-1997 provides more detailed provisions entrusted by the Act. Regulatory Body Bangladesh Atomic Energy Regulatory Body was established under section 4 of the BAER ACT-2012 for carrying out the purposes of the Act-2012

7 7 The objective of the act is- to establish an independent regulatory authority for regulating nuclear safety and radiological protection to ensure the protection of human life, health and living conditions of both present and future generations, the environment and property from the harmful effects of ionizing radiation to ensure safety and security of nuclear material and radiation sources to enable Bangladesh meet its international obligations on the peaceful uses of nuclear energy

8 8 Governmental and Legal Framework for Safety Legal Aspects (According to BAER Act- 2012) Establishment of Independent Regulatory Body Authorization Process Radiation Protection Safety and Security of Radioactive Materials Nuclear Safety Physical Protection of Nuclear Material and Installation; Safeguards and Import and Export Control State System of Accounting for and Control of Nuclear Material (SSAC) Transport and Waste Safety Emergency preparedness and Response Nuclear liability and coverage, etc. Inspection and Enforcement Offense, Trial and Penalty

9 9 Governmental and Legal Framework for Safety Management System of Authority The Authority shall consist of a Chairman and 4 (four) Members. To perform its duties smoothly, the Authority may appoint sufficient number of employees according to the organogram approved by the Government. Resources The Authority shall have a fund of its own. The fund shall be accumulated by the following, namely- funds granted by the government annually; fees and charges deposited under this Act; grants received from National and International Agencies with prior approval of the Government; and money received from any other source with prior approval of the Government Independence The Authority shall be a Statutory Body and it shall have perpetual succession and a common seal with power to acquire and hold moveable and immoveable properties, to transfer such property subject to the provisions of this Act or Rules and Regulations made under the act and may, by the said name, sue and be sued

10 10 BAERA role s issue, amend, suspend or revoke authorizations; define exclusion; define and grant exemptions from regulatory control establish a schedule of fees establish limits of radioactivity into soil, water and air and in any matter usable as food. formulate or adopt necessary policies and issues and implement orders or instructions in areas of its responsibility; establish and maintain human resources development programme for its employees

11 11 BAERA role s establish a public participation system through seminar, workshop, electronic and print media and internet, etc for information and consultations with interested parties about the possible risks associated with facilities and activities; publish related information and communicate with relevant agencies, the public and media; establish and maintain a national register for radiation sources; establish and maintain a national register of persons authorized to carryout activities or practices under this Law

12 12 BAERA role s establish and maintain a State System of Accounting for and Control of nuclear and radioactive material (SSAC); liaise and co-ordinate with other governmental or nongovernmental bodies liaise with regulatory bodies of other countries and with international organizations approve an effective reporting procedures with respect to radiation incidents establish regulatory measures for the security of nuclear and radioactive material and their associated facilities perform any other duties prescribed or assigned to the Authority by the Government from time to time as deems necessary to meet its statutory obligations.

13 13 Regulatory Framework for Safety Legal requirements Chapter 3 of BAERA-2012 described licensing procedure and section 51, 52 of chapter 8 described the inspection and enforcement procedure Section 18 Licensing No authorized person, operator or overseas operator shall site, design, construct, commission, operate, and decommission any nuclear installation or radiation facility or close radioactive waste disposal facility and release the site from regulatory control without holding an authorization issued by the authority under the regulations in a prescribed manner Section 51(1) (2) Inspection The Authority shall appoint adequate no. of scientist and engineers to carry out regulatory inspection as per Regulation made under this act Any establishment, facility or activity holding authorization, applicant for authorization or unauthorized or not notified, located in any place within the territory of Bangladesh shall come under regulatory inspection 13

14 14 Governmental and Legal Framework for Safety Section 52 Enforcement (1) If any authorization holder- Violets any provisions of this Act and Rules or Regulations made there under or the conditions of authorizations applicable in case of action or services; and Obtain authorization by providing incorrect or misinformation -then a notice shall be issued to that person to show cause within 30 days as to why he or she not be punished and the authorization shall not be suspended or cancelled (2) The notice delivered in subsection (1) shall have specific description of the nature of violations and amendment or remedial action; provided that the authorization holder shall be obliged to perform the above mention measures by his own responsibility within specified time up to the quality accepted by the Authority (3) If the Authorization holder fails to comply with the notice under the subsection (2) the Authority may lock and seal or cease the operation of any nuclear installation or radiation facility as applicable (4) For implementation of the activities, mentioned in the notice under subsection (1), the Authority may request any law enforcing agency or any other government Authority for necessary assistance 14

15 15 Regulation NSRC Rules the NSRC Rules 1997 (SRO No.205-Law/97) was formulated by the BAEC and notified in the Bangladesh Gazette on 18 th September 1997 NSRC Rules are based on IAEA Basic Safety Standards 115 & ICRP-60 (1990) Recommendations

16 16 Important Features of NSRC-Rules 1997 Chapter II Rules 7: Requirement of Licence Chapter III Rule 10.1: General Requirement of Licence Rule 10.2: Classification of Licence Rule 10.2(e): Class F Licence- is a licence to site, to start up or to full operation of nuclear/ research reactor Rule 10.3: Stage of Licence Rule 11: Import and Export Permit for nuclear materials Rule 12: Nuclear/ research Reactor Operator Licence

17 17 NSRC-Rules 1997 Chapter III Rule 15: Applicable Standard, Code and Guide Chapter IV Rule 17: Safety Requirements Rule 17.1: General Requirement Rule 17.2: Security of Source Rule 17.3: Safety Requirements at Different Stages of Licence

18 18 NSRC-Rules 1997 Chapter IV Rule 18: Technical Requirement Rule 19: Management Requirement - quality assurance, safety culture, human factors, education and training Chapter IX: Rule 81: Protection of Licensed Materialthe licensee shall take appropriate measures to protect all radioactive materials, nuclear materials, prescribed substances, irradiating apparatus and facilities to prevent theft or sabotage

19 19 NSRC-Rules 1997 Other applicable Rules which covers occupational exposure (Rules 20-21) public exposure (Rules 36-42) potential, emergency and chronic exposures (Rules 43-50) operational exposure control (Rules 51-85) Emergency Preparedness (Rule-77) transportation of radioactive material and waste management (Rules 86-87) Bangladesh /IAEA/ International and bilateral agreement (Rules 88-90) and enforcement (Rules 91-99)

20 Applicable standards, codes and guides 20 Among others, a list of applicable standards, codes and guides for research reactor operation, design, safety assessment, utilization & modification, commissioning, decommissioning, etc. is incorporated in Schedule - IX of NSRC Rules-1997.

21 21 Regulatory Control of Operation and Maintenance of the Reactor The operation and maintenance of the 3 MW TRIGA MARK- II research reactor Facility (TRF) of BAEC is controlled by the Technical Specifications drawn from safety analysis report

22 Approval of experiments & modifications 22 There are AERE based local safety committees for review and approval of any experiment or utilization of the research reactor For any modification in the reactor system BAERA will review the matter and approve

23 23 3MW TRIGA Mk-II Research Reactor of BAEC The only RR in Bangladesh USES Training Research Isotope production General Atomics Reactor Power: 3 MW

24 Research Reactor 24 3 MW TRIGA Mark-II Research Reactor (RR) attained its first criticality on 14 September, The reactor is being maintained totally by BAEC personnel without taking any assistance from any local or foreign agency BAEC, using its in-house capability, upgraded the Safety Analysis Report (SAR) of the RR following the IAEA Safety Guide SG-35 G1.

25 25 3MW TRIGA Mk-II Research Reactor (TRF) Of BAEC Location: Atomic Energy Research Establishment, Ganakbari, Savar Supplier : General Atomic of USA Installation started : 1980 Achieved Criticality : Sept. 14, 1986 Owner of TRF : BAEC Operated by : Reactor Operation and Maintenance Unit (ROMU). Licensee: Director, ROMU

26 26 Regulatory Inspection Inspection Plan Routine Inspection: Announced Inspection : 1 times per year and before renew Un-announced Inspection : No Safeguard Inspection: BAERA Safeguard Inspection : 1 time per year IAEA Safeguard Inspection : 1 time per 2 yrs Inspections are done in a prescribed form

27 27 Methods of Inspection Monitoring and direct observation such as working practices and equipment Discussions and interviews with the personnel of the operator Examination of procedures, records and documentation Tests and measurements

28 28 Inspections during Operation Inspection regarding Operation, Engineering and Maintenance are conducted during operation of RR to ensure the compliance of applicable requirements (i.e. national regulations, applicable procedures, codes & standards, regulatory guides etc.)

29 29 Inspection Areas during Operation Operation Maintenance Surveillance Engineering QA Training & Qualification Emergency Preparedness Radiation Protection Fire Protection Radioactive Waste management Environmental Monitoring Physical protection In-service Inspection

30 30 Licensing Approach of TRF BAEC was established earlier than BAERA 1980 Installation Started of TRF 1986 Achieved Criticality Establishment of NSRCD Establishment of BAERA Initially Research Reactor is not licensed A detailed inspection was conducted during 48 hours continuous operation (11-13 June 2002) [see its endurance performance as a part of re-commissioning followed by major modifications of the cooling system mainly with replacement of decay tank and heat exchange] licence was issued to the reactor facility for the first time on 20 May 2003 for a temporary period of one year [decided that consideration for a full-operation licence would only be made upon approval of the SAR] Temporary licence, was renewed for 4 (four) times First regulatory inspection with a prescribed form approved by the commission was conducted from February 2004

31 31 Licensing Approach of TRF Safety Analysis Report (SAR) of TRIGA Reactor Facility (TRF) was approved by the Commission on 25/10/2007 ROMU applied for full operational licence on 02/3/2008 for 5 yr Full-pledged operation license to the TRIGA reactor facility on 1 st June 2008 Validity of license was up to 30 th May 2013 Facility applied for renewal Issuance of license is under process At present the reactor is being operated at a steady state power level of 2 MW as per decision of the Commission BAERA make necessary arrangements for regulatory inspection at least annually for compliance of license requirements and monitoring safety of the reactor

32 32 Certification Scheme of RR Operator Education Criteria RO (Reactor Operator) BA/Msc/Bsc Engineering SRO (Senior Reactor Operator) Msc/Bsc Engineering Experience 1 yr./5 yr 5 yrs. RO certificate Training Receive training from ROMU Receive training from ROMU Medical Requirements Examination Medically fit Comprehensive written (7 paper) Facility walkthrough Oral and Practical Examination) Operating Comprehensive written(5 paper) Facility walkthrough Oral and Practical Examination) Operating

33 33 Conclusion National measures through law and regulations are applicable to achieve and maintain a high level of safety in research reactors which is the objective of the code of conduct