ML20043D843

Informs Commission About 900517 Meeting W/Tattersall,Chief Executive of South African Council for Nuclear Safety to Discuss Broad Nuclear Safety Issues

ML20043D843
Person / Time
Issue date:	06/07/1990
From:	Harold Denton NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA)
To:
References
TASK-PII, TASK-SE SECY-90-203, NUDOCS 9006110218
Download: ML20043D843 (49)

Text

{{#Wiki_filter:, oo.ee...eeeee.o. ..ooo. /.'" %, RELEASED TOTHE PDR ~ i 1 (m ch' \\,,,,,,,,/.: =. >olnw/90 ............ p.ats ir POLICY ISSUE (InfOrmatlOn) sEcY-90-203 June 7, 1990 L [ar: The Commissioners [rge: Harold R. Denton, Director Office of Governmental and Public Affairs Subiect: MEETING WITH THE CHIEF EXECUTIVE OF THE SOUTH AFRICAN COUNCIL.FOR NUCLEAR SAFETY - MAY 17, 1990 c

Purpose:

To inform the Commission about a meeting with Mr. Tattersall, Chief Executive of the South African Council for Nuclear Safety, involving members of GpA and State Department representatives. Discussion: On May 17, 1990, I met with Mr. John 0. Tattersall, the Chief Executive of the South African Council for Nuclear Safety, at the State Department to discuss broad nuclear i safety issues, m Mr. Tattersall provided us with the Council for Nuclear Safety Annual Report 1988/89 and information on their nuclear safety standards and their application. Palosed is a copy of the meeting summary, including the South African submittals. South Africa has two French-built 950 MWe (Koeberg Units 1 and 2) operating nuclear power plants. The plant has esi blished risk-based goals, and is operated with the objective of maintaining these goals. (A summary of the Fundamentals Risk Standards can be found in page 5 of - of the 1988/89 Annual Report in the enclosure, and more details are in "Some Limited Revisions to the Nuclear Safety Standards and Their Application" also in the same enclosure.)

Contact:

Victor Benaroya, GPA/IP X-20653 4 NOTE:-TO~~hsEMADb"PUBLICLYAVAILABLEIN10WORKINGDAYSPROM [, j ~ THE DATE OF THIS PAP J _ WPMM l

I.. 7 s -.o The Commissioners 2-Mr. Tattersall was pleased to have the opportunity to meet with U.S. Government officials to discuss nuclear safety and expressed an interest to maintain a dialog in this area. We do not intend to take any specific followup actions. / Harold R..Denton, Director Office of Governmental and Public Affairs

Enclosure:

Meeting Summary DISTRIBUTION: Commissioners OGC IG GPA EDO ACRS ACNW ASLBP ASLAP SECY L 4 e- !i i

) /p>* #80p ' NUCLEAR REGULATORY COMMISSION l' q'( UNITED STATES i ) ( WASHINGTON. D. C. 30666 May 31, 1990 ( %..+ / MEMORANDUM FOR: Ronald D. Hauber, Director, GPA/IP FROM: Victor Benaroya, AD for IPRSC, GPA/IP V

SUBJECT:

MEETING WITH MR. TATTERSALL, CHIEF EXECUTIVE OF THE SOUTH AFRICAN COUNCIL FOR NUCLEAR SAFETY l On May 17, 1990, Mr. Harold Denton, Director, GPA, and Mr. Victor Benaroya, Assistant Director, GPA/IP, attended a meeting at the State Department with State Department representatives to meet with Mr. John Tattersall, Chief Executive of the South African Council for Nuclear Safety. Those who attended are listed in Attachment 1. Mr. Tattersall provided an overview briefing on South Africa's nuclear regulatory structure. The South African Council for Nuclear Safety has 74 people, 59 technical and 15 administrative. It is responsible for the safety overview of the two units at Koeberg, in addition to all nuclear fuel cycle activities, including radioactive wastes. Mr. Tattersall explained that because of political realities and lack of reliable su) ply sources, South Africa had to build its own enrichment and fuel faarication facilities. These facilities have the capacity to supply about ten nuclear units, whereas there are only two units in operation. There are no near term plans for building additional units, because at present South Africa is enjoying an oversupply of electricity. Koeberg Units 1 and 2 are 950 MWe (2782 MWt) PWRs, built by framatome of France. They went into operation in 1984 and 1985. The Nuclear Safety Council maintains two residents at the site. There is adequate storage for spent fuel for about 30 years. The plant has established risk based goals, and is operated with the objective of maintaining these goals. The PRA was prepared by framatome, although with reluctance. The operating utility, Escom, has a simulator, but the Council for Nuclear Safety has not used it to train its own personnel. They would like to use NRC's TTC. The operator qualifications requirements seem to be similar to ours. The Senior Operator in the control room has a college degree. They administer psychological tests to operators, and according to Mr. Tattersall, one or two were found to be undesirable. The Nuclear Safety Council has the authority to request the Justice Department to levy fines; however, because of the cumbersome procedures, none have been levied thus far. Mr. Tattersall provided us with the Council for Nuclear Safety Annual Report 1988/89 (Attachment 2). Mr. Tattersall is visiting the regulatory organizations of several countries. He asked our opinion as to whether a WANO type organization for regulators to exchange information and solicit opinions would be beneficial. The personal opinions expressed can be summarized as:

1) there are adequate international bodies already available for such a forum, 2) bilateral discussions seem to be more fruitful, and 3) we do not have resources to take an additional task.

r s 1 O k 1 Ronald D. Hauber May 31, 1990 I Mr. Tattersall was pleased to have the opportunity to meet with U.S. i ~ Government officials to discuss nuclear safety and expressed an interest to maintain a dialog in this area. We do not intend to take any specific followup actions. Attachments: As stated cc. H. Denton K. Henderson M. Peterson R. Senseney, OES/NEC, State r f i F \\ b l. i 7 I-k - - - - _ - - - - = _ _ - - - _ - - - - -, - - - -,. - - - _. _ _ _ -

41 Y DEPARTMENT OF STATE

• ~

Wa: Nation, D.C. 30530 DATE: Thursday, May 17, 1990 j TIME: 10:00 a.m. LOCATION: Conf. Rm. 7531 GUEST: John O. Tattersall, Chief Executive of the i south African Council for Nuclear Safety TOPICS: Discussion of broad policy issues and practices of safety regulation, including: j

• safety goals
• structure, staffing and experience of 07 regulatory bodies Ap* use of consultants
• role of international bodies such as the International Atomic Energy Agency
• safety research
• control over qualification and training of operators
• enforcement and penalties
• current, major safety issues NUCLEAR REGULATORY COMMISSION Harold R. Denton, Director, Office of Governmental and Public Affairs (GPA)

Victor Benaroya, Assistant Director for International Cooperation, International Programs, GPA L DEPARTMENT OF STATE Robin DelaBarre, Acting Director, Office of Nuclear Export L Control, Bureau of Oceans and International Environmental and-Scientific Affairs (OES) Robert Cabelly, Special Assistant to Ambassador at Large for Non-Proliferation Policy and Nuclear Affairs l l Ray Clore, Sr. Analyst for Latin America and Southern Africa, Office of Non-Proliferation and Nuclear Export ' Control Policy, OES ARMS CONTROL AND DISARMAMENT AGENCY Robert Summers, Chief, Division of Nuclear Safeguards and Technology, Bureau of Nuclear Weapons Contr31 l Deborah Bozik, Division of Nuclear Sateguards and Technology, Bureau of Nuclear Weapons Control i ATTACHMENT 1

y 333 y J COUNCIIf ~ \\ y I ~ ?. ~ Y; ~ ~ 37 EREPORTW L1988;89 2' ., x ~ ATTACHMENT 2

a. It is the Council's statutory responsi-bility to safeguard the public against nuclear damage, by the exercise of regulatory control over the construc-tion and use of nuclear installations as well as over any other activities which involve nuclear hazard mate-rial

• and which are capable of caus-ing nuclear damage.

p I l. l 1 As defined in the Nuclear Energy Act l j (Act No. 92 of 1982) as amended. i l s e-

Table of Contents \\ Page l Chairrnan's Foreword 2 Introduction by the Executive Officer 4 Structure of the Council 9 j 1 Meetings of the Council 18 Council for Nuclear Safety Regulatory and other actMties 19 Annual Report 1988 - 1989 cencric studies 23 Participation in Meetings and Conferences 24 Conclusion 24 k' ' Financial Statements 25 Na..., the Financial Statements 27-4 I e 9 r s-

y ~ 2 A major mileston l 1 i ment of regulatory control of the nucice-industry in South Africa was reached in 1988 with the emergence of 04 Council for Nuc' ear Safety as a fully independent regulatory body. s The Council was established in 1982 as an independent body with consultative functions in the process of the issue of nuc! car licences by the Atemic Energy Corporation. The Council did not have its own staff, but considered proposals formulated by the Licensing Branch of the Corporation. The Council's functions were limited to making ree-ommendations to the Corporation with regard to the issue of licences; l in the event that the Corporation did not accept the Council's recom-mendation, the matter would be referred to the Minister of Economic Affairs and Technology for resolution. l 1 With the promulgaHon of the Nuclear Energy Amendrmnt Act in June 1 1988, the Council for Nuclear Safety became a juris:1.: person and-t assumed regulatory powers over nuclear installations and actMtics l involving nuclear hazard material which were previously vested in the - Atomic Energy Corporation. Chairman's ^iihet iime members ef the former Comecii-re re enneinied bv the L Minister to serve on the recoratituted Couned. The members of the I- 'breWrd Council dring together a wide range of knowledge and experience in nuclear and public safety. To enable the Council to deal with its substantially increased responsi-b!htles and extended functions, the exxutive technical and support staff of the Licensing Branch of the Atomic Energy Corporation were transferred to the Council; as provided for in the Act. The Council and its staff moved to its own premises in Verwoerdburgstad in October L 19 S 8. ~* ym, b .. 1 i. ( I~ I i1 1 l lA ~ .M{ N[ ~ g* ~ " 7 hfembers of the y, Council. Left to 3 righ t t htr E L s ,s Langford, hfr B C

• ~

Winkler, hfr P J 's Le Roux, Dr P D of regulatory control, are prepareditora ir. formation and l.. requirements cet down by the technical departments. To ensure that appropriate ss(ety requirements are consistent with changing circumstances.th department maintains close liaison with the techni- '*I d'P*'t"" ' 'd ***"d5 8' 'd 5"" li(*"C'5 *h*"*" "5~ Saiety requirements rnust be con- '* G'- sistent with changlag circum-stances The department provides a legal service to the Council and advises on commercial matters and on matters relating to regulaton' legislation. It j has also handled the implementation of international safeguards re-quirements in respect of nuclear facilitics and ' material. s 6 t I ~ ~, i 4 k bfr C L' La ngfo rd, blanager Centrol Services Depart-ment 17

m w i ^ a r c "w ys '- fpW" + N; u Technical, scientific and legal informati n is an essential weapon in the T Council's regulatory armoury.- Access to all the Council's information $j ' and data will be greatly facilitated by a computerised system currently M" being installed in the Council's offices anct for which the_ Central =

• e ' '..

Services Department will assume responsibility after commissioning. y o P This department is also responsible ict the Councits financial and - i personnel matters. It provides the Cour. ail with a secretariat and it ?

• attends to all other administrative matters, including those associated with the Councits officts.

ym .r.. > ~ y p' 4 t t kib J y c Meetings of the m ' ggg _ Councilwere held prior to the amendment of the Nuclear Energy Act h in Jane 1988. At the meeting in January 1988 the Council received %a . presentat!cns by members of the AEC Licensing Branch on damage to i fuel assemblies and on rnechanical snubbers at Koeberg Nuclear _ 1 Power Station. At its meeting in March 1988 a presentation was given by Eskom on its ]r nuclear organization. - During the remainder of the period under review a further five s.heduled meetings were held. one of which was in in conjunction with a nature conservation course presented by the Na-4 l tional Parks Board at Skukuza. At its meeting in March 1989 a 1 l presentation on Basic Safety Philosophy was given by the Executive Officer. The Council meeting in November 1988 was attended by the Minister. In addition to these meetings Council members have made inspection I. visits to nuclear installations at the Atomic Energy Corporation's sites L at Pelindaba, Valindaba and Vaalputs. 7 The Councits Technical Committee and Health Physics Committee have each met once since they were established towards the end of t 1988. ,t Il 1 ri' g c18' s <-.2

-..-..-,-m... oeberg Nuclear Power Station Licence Variations A variation of Licence No KL 1, issued by the AEC, was required to cater for the increased storage capacity of the spent fuel pools the cmschdation of in sennce inspection requirements, and the incorpora-tion ci an ope,3 ting requirement into the plant's operating technical snecifications Since the regulatory function had been transfetTed to the Council a new heence, NL4, was issued covenng e!! the require-ments of the former heence and providing for these changes Training of Operational Staff The Council has continued to satisfy itself that the control room opera-tors meet the required standards of performance. To this end staff of the Council, assisted by consultants. have b.een involved in assessing the psychological suitabihty of control room operating staff, and have I administered examinations to assess their knowledge. skill and ability OG ad agninst the Council's standards. Since January 1988 eighteen candidates have been examined and ten e Oth. er ACt1VitleS acactor operator acences anci six Senior acacior operator hcences ham been issued Over this penod thirty-nine operator hcences have beer, renewed Ernergency Preparedness The Councilis committed to the continued effectiveness of emergency planning provisions for Koeberg The regional imphcations of such planning are addressed by the Emercency Planning Liaison Committee on which the Cape Town City Council. the Western Cape Regional Services Council, the Cape Provincial Administration, the Department of Prisons, Eskom and the Council are represented. This committee was estabbshed by the Licens!rtg Branu of the Atomic Energy Corporatior The role of the latter has been assumed by the Council which now provic'e3 the Chair

• nan and <,ecretariat.

Staff of the Council prepared a scenario for a full scale emergency exercise to be carried out by Eskom and involving mobihzation of the resources and f acilities of off site participant organizations Refuelling outages During the penod covered by this report both units were shut down f or scheduled refue3ng and routine mamtenance These activities were montored by Councilinspectors and a,ppropriate reports were submit-ted to the Counc.i in September 198S when unit 2 was refuelled. the first 4 fuel assembhes of South African manuf acture. having satisfied the Council's requirements. were dehvered to Koeberg and Icaded into the core 19 ac d$

, d ;.; - p, a s g e-L afety related Matters!, {3 W, Staff of the Council's technical departments have been engaged in monitoring all aspects of the operation of Koeberg. Routine technical assessment work has been carried out in respect of e* operating occurrences: plant modifications, amendments to the li-7 'cence, to the operating technical specifications and to the operating. procedures; and various submissions and reports. 4 Monitoring of routine operational radiological protection aspects at Koeberg has been undertaken by the continuous review of occupa-4 tional radiation doses accrued, the quantities of radioactive elfluent dis- ' charged into the environment, the quantities of radioactive wastes generated and the results of environmental monitoring. In addition, abnormal incidents directly related to radiological protection have been assessed on an ongoing basis' together with procedural and c-equipment changes requested in terms of licence conditions. - A wide range of reactor physics studies has been carried out in The results of Eskom quality assurance audits together with Councilin-order to su 3 port an extended low spections and audits have also been included Jn the overall assessment power moc e of operation of the-of the adequacy of the provision of radiological protection. < Koeberg reactors hi the area of general safety support, work has been done on the E generation of audits: the development of licensing tasks; improvement of the risk based methodology on.which the South African licensing process is based; the development of probabilistic licensing guides: in-depth studies of particular safety issues and the maintenance and up-dating of technical skills. Progress has been made both by Eskom and by the Council towards the oevelopment of a computerised probabilistic risk assessment model to be used as an elficient tool for rapid licensing decision making. C The in-service inspection programme for Koeberg was completed - a task involving several man years of effort on the part of both the Council and Eskom. The maintenance programme for Koeberg was further advanced and is now near completion, having also involved a number of man-years of effort by both the Council and Eskom. t Significant progress has been made in the development of computer = W..S codes as licensing tools for the analysis and evaluation of reacter core 2 reload safety reports. k A wide range of reactor physics studies has been carried out in order to support an extended low power mode of operation of the Koeberg E reactors. Thh involved a number of changes both to the Operating Technical Specifications and to certain operating procedures all of-P_ i which required approval of the Council. One of the major Koeberg modifications completed during the past year concerned the replacement of the existing spent fuel pool racks g;i t

This by high density racks in order to increase storage capacity. involved a c'etailed analysis of the adequacy of using the cask loading cell as a temporary storage for fuel assembhes whilst the modification took place This was found acceptable to the Ccrr.cil follow,ng a com-prehensive probabihstic structural analysis. Owing to difficulties associated with the performance of snubber supports. particularly those associated with the steam lines. Eskom embarked on a comprehensive analysis of supports with the aim of replacing cenain of these, both inside and outside the containroent. wnh fixed restraints. The Council carried out a range of structural studies to determine which snubbers could be replaced by fixed supports in such a manner that safety was not compromised. During fuel loading parts of the fuel assembly support structures received minor damage. Extensiw investigations were carried out with the aid of recorded video pictures of the damaged assembhes to ensure that the f uel pins in the assembhes which were loaded into the core had not. themselves. been damaged The pnnciples of quahty management apply to all aspects of nuclear The principles of quality manage-Safety. and the Council has played an active part in the continuing ment apply to all aspects of nti-deve!^pment of Eskom's quahty management approach in support of clear safety the Council s risk philosophy. All matters relating to nuclear safety are regulated through the hcence which is consequently kept under continuing review by the Council s staff. necessitating periodic changes to the text and attendant docu-mentation. .s b i o s I 4 w Members of the Cou.,cil [7 ' ~ visit the No. $m tional Radio-active Waste 4yK Repositoryat y .g D L Vo a lp u t s, ~ 4 sinfnb ti .n i 21

ww.. l.I!b r w .o. w.- s au + F +e tomic Energy Corooration-e Plants and Activities p, e A consequence of the Nuclear Energy Amendment Act of 1988 is that .E facilities operated by the Atomic Energy Corporation, which were required under the previous legislation to conform to the same health and safety provisions as were applicable to licensecs' facilities, are now w subject to the formal licensing process. The necessary technical and. ,4 administrative work of preparing the appropriate licences was com-' P.. menced during the period under review. V Inspectors of the Council have monitored actMties at C.s Pelindaba ano Valindaba sites, and at the National Radioactive Waste Repository at Vaalputs. Discharges of radioactive effluents from these sites have - 7 remained within the limits laid down. A system of effluent dise.harge limitation, based upon the same principles as are applied to Koeberg, l has been established for implementation. .n m , Consideration has been given to problems associated with the ef-Future Power Station Sites fluent discharges from mining op. erations In accordance with the Minister's expressed wishes the Council has been closely involved with Eskom in the selection of suitable sites for possible nuclear power stations. Following a request from the Council, Eskom applied for licences for thres sites in the Eastern Cape Prov-ince, thereby enabling the Council to formally seek information which it required from Eskom in order to pursue its assessment of these sites. Other Nuclear Activities Other activities invoMng nuclea* hazard material can be divided into three main areas, namely : 't

• rnining and processing of uranium and thorium bearing ores
• other operations invoMng such materials including, for example.

monazite processing plants, as well as the burning of pyrites in sulphuric acid plants

• users of small quantities of nuclear hazard material, usually as labo-ratory reagents.

The first category has been under consideration for some time in con. Junction with the Government Mining Engineer, with a view to control-ling the activities through the provisions of the Mines and Works Act, to ensure adequate radiological safety as provided for in the Nuclear Energy Act. 4 22 -- 1 .n z -r

k e in view of ecrtain shortcomings in the existing Mines and Works Act it was decided, in consultation with the Government Mining Engineer and as an interim measure, to proceed with licensing in terms of the Nuclear Energy Act. Preparation of the necessary standards has been - under way to enable the affected facilities to be' licensed. Assessments of several facilities in the second category have been carried out, and the disposal of waste from decommissioned sulphuric acid plants and rehabilitation of the sites which are contaminated with uranium daughter products, mainly radium, have been addressed.- A generic set of licence conditions for users of small quantities of 5 nuclear-hazard material has been established and a guide document for such users drawn up. Several such users have been issued with licences. Consideration has been given to the problems associated with liquid effluent discharges from mining operations and an investigation was stoned in co-operation with the Department of Water Affairs. Results of the investigation to date clearly indicate the need for controls, and this aspect is being addressed. Generic Studies L i l l. 1 s i he Council, through its Generic Studies Division, has sponsored research programmes in fracture and - structural integrity and as a result is a-full member of the International Cyclic Crack Growth Committee and the Irradiation Assisted Stress Corrosion Cracking Committee whose objective is to set safety stan-dards and develop manufacturing procedures, in addition the Council is a task group leader in an international programme 'of metallurgical examinations of failed stainless steel reactor internal components.' q The division has pioneered the downloading of an atmospheric disper-sion modelling computer programme from a mainframe computer for use on a personal computer. Work has continued on human reliability studies and on developing the ap;:lication of so-called artificial intelligence to the compilation of a data base for the Council's computer system. 1 23

y y = ls. E,; y f 'a tis essentialfor the Council'swork that its staff keep abreast of international developments over a wide. (F spectrum of science and technology pertinent to the nuclear industry ,1 and its regulation, A large number of conferences and symposta are held every year at which international experts present and discuss papers of interest and value in this sphere, and members of the Council's staff have partici-- pated in a selection of these appropriate to our more immediate needs.- Five members of staff have attended conferences in France and Italy on

• accident analysis, risk assessment, operational safety and environ-mental impact.

Two members participated in international workshops on; respec-tivelv, operational safety performance indicators of nuclear plant, organised by the International Atomic Energy Agency in Vienna; and-radiological protection in mining. organised by the International Ra-diological Protection Association, held in Danvin, Australia ~. At the latter Mr P E Metcalf Manager: Standards Department, presented a - paper on regulation of radiological protection in the South. African b r =t"t"s *d"s

• L Participation in 1 Meeting' sLand Mr s c war. oegev cen-ei "-se es e membe er commma 4 of the international Commission on Radiological Protection.' at-l:

L -Conferences tended thereeeier meetines ofthe Com mittee. heidin ^ustrie.ihe i p United Kingdom and the United States of America. l; i Mr J Leaver, Deputy General Manager, was an adviser to the South African delegation to the Eleventh Meeting of Contracting Parties to l the Convention on the Prevention of Marine Pollution by Dumping of p i Wastes and Other Matter, held in London. in addition, Dr K D Bogle, Head: Generic Studies, as the representa-tive of the Council, presented papers entitled 'The effect of environ- = ment on crack growth'. and "Some aspects of stress corrosion crack-L J ing", at meetings of the international Cyclic Crack Growth Research L' Group. and the Irradiation Assisted Stress Corrosion Cracking Group respectively, held in Sweden and Finland. f ?! i Conclusion 3 L< Nuclear safety is at the highest strategic level in the socio-political development of the Republic and its peoples. The Council, conscious of its responsibility, is playing a proactive role in its insistence that nuclear facilities and nuclear hazard material must L. not impose an unacceptable risk.' TMs demands a broad and deep a y understanding of all facets of the pelear industry and associated JI technology and their interactbn with tne popubtion and the envirort ment. f in striving to meet this challenge the Councilis making use of the most modern technology and high4 qualified manpower. t' I i l

m Income Statement for the Period ILJuly 1988 i to 31 March 1989 Notes 1988/89 >1 R income

7 756 137,00 L

State contribution via AEC 5 386 890,00 l Licensing fees 1 406 496.00 ~ Interest 79 493,00 -Financial sund,y 883 258.00 Statements cess Expenditu,e S o.3 40s 00 P'ersonnel expenses 3 362 365.00 Subsistence and transport 822 957,00 . expenses Consultancy 39 664.00 Publications 1 349,00 Rent, accommodation - 430 774,00 Repairs and maintenance 534,00 Research contracts 203 503,00 Postal, telex and telephone 34 033,00 services Consumable stores - 195 557.00 Provisional expenditure 2 78 302.00 597 181.00 Sundry expenditure 3 Depreciation '200 187,00 Income over expenditure 1 789 731,00 l f 'l / J O Tattersa!! E o Langford Executive Officer Manager : Central and General Manager Services Department Verwoerdburg, 89.07.18 25 i 'f .j_

,l*/,, % y l. 1 Balance Sheet as at 31 March 1989 1 1 Notes '1988/89 R j CAPITAL EMPLOYED Capital 4 180 799,00 y General fund 1 789 731,00 1 970 530,00 EMPLOYMENT OF CAPITAL l The financialstatements represent Fixed assets 5 .981 549,00-the financial position of the Coun-cil as at 31 March 1989 Net current assets 988 981,00 4 Current assets 2 069 921,00 1 '1 Petty cash Council for '1 000,00 Nuclear Safety Petty cash for 400,00 Koeberg site office Petrol deposit. 2 000,00 Key deposit 20.00 Bank balance 2 066 501,00 Less : Current liabilities .1 080 940,00' Sundry creditors 6 1 080 940,00 1 970 530,00 The accounts of the Council for Nuclear Safety have been audited in ?

i.1 terrns of sections 5 and 18(2) of the Auditor General Act, No. 52 of 1989, read with section 26(4) of the Nuclear Energy Amendment Act No. 56 of 1988 and in my opinion the annual financial statemects are i

a fair. representation of the financial position of the Ccancil as at 31 l E 4 March 1989 and the result of its operations for the year then ended. 4 Pretoria. 89.08.28 Auditor-General 26 ' n

t u ,,1 ,qr -,1 l q;" e h; ~ 1.' Accounting policy o 1,1 Introduction The financial statements were compiled on the historical cost basis during the Council's first year of existence 1.2 Fixed assets ' + Furniture and equipment are valued at cost price minus accumulated depreciation - 1.3 Depreciation of fixed assets - Furniture and equipment are wTitten off on a straight line basis over the expected usefullife of the asset Notesoto;the financial

2. Provisionai expenditure StateinentS.

Payments in respect of expenditure incurred by the old' Council for Nuclear Safetv in terms of the budget administered by the Department of Minera! ad Energy Affairs before the institution of the new Council,

3. Sundry expenditure 1988/89 R

Stationery and printing 18 350,00-Entertainment 6 067,00-Membership fees, professional associations 3 367.00-r- Cleaning services t 6 990,00 Insurance 9 867.00-Maintenance and service contracts 4 982.00 ' Computer time 68 431,00 t

AEC debit 420 000.00

- Small items 386,00' Analytical chemistry ~ 3 041.00 Translation work -2 190.00 - Small works 12 758,00 - Medical and whole body count expenses 720,00 Small capital items, each less than R5 000 40 032.00 597 181.00 t

4. Capital s

Assets taken over from the AEC 180 799.00 27 e a

> vJ n j b. D S}f,, 1f,3% a y

l,,., (, 4.

.y ci-j.,

~ s

5. Fixed assets 1

(Furniture and equipment) m" 1988/89 R \\ Assets purchased ^ 1 000 937,00 x Less : Depreciation 200 187,00 ? I A:sf 800 750.00 L-i UfM-Plus i Assets taken over from the AEC 180 799,00 (:l:$, 981 549,00'

6. Sundry creditors 1988/89 R

Salary deductions 16 389,00 . The ' financial" statements were Claims for subsistence and transport 2 391,00 compiled.~on -the historical cost - outstanding payments to suppliers 1 060 960,00 basis: Licensees' security deposits 1 200,00-s. i 1 080 940,00 t 1 ~'.. 1 Z 1 i; _,g,i s s 2 i = 28~ c t

CNS lSf87 s 7, oj 1 APRIL -1987' %s: '90ME' 11 MITED REVISIONS ! TO OUR NUCLEAR SAF'ETY STANDARDS AND THE R I APPLICATION-H L 1.. Introduction g

s'%

The Nuclear Ener gy Ac t, No. 92 of 1982, which incorporates, ,Y ' inter alia, the-substance of the original-Nuclear Installa-tions (Licensing and. Security) Act, No. 43 of 1963, charges the Atomic Energy Corporation of SA Limited. ( AEC ) and the u Council for ; Nuclear Sa f ety (CNS) with the task of ensuring adequate protection for-South African society against N nuclear damage as defined in th e - Ac t. Th e - Ac t prohibits l. persons-from possessing, prod ucing,

storing, processing, l-reprocessing, conveying or disposing of nuclear hazard I,

material without the authority of a licence granted by the AEC, 'with attendant conditions approved by the CNS. The need for a licence is waived in those cases where the AEC, on the recomcendation of. the CNS, declares in writing that L in its opinion the risk of nuclear damage cen under no~ cir- -cumstances exceed limits -consistent with health.and saf ety. l l (! -2. Current Safety Standards L Thd nuclear safety standards currently applied were origi-nelly developed et the beginning of the ~ 1970s by ~ the Licen-sing

5. ranch cf the then AEE in' consultation of the Board's l

o' Nuclear Safe y Advisory Committee and - were subsequentl y - endorsed by the CNS when it was first formed.in terms of'the. l Nuclear Enerev A:: of 1982. l L Yne results cf the extensive studies of the early '70s may be briefly suc arised as f ollows : L F Since nothin: ma n-ma de can be absciutely safe, we must licence on - a basis of acceptable risks. In developing current standards-it was - considered that, ideally, the risk jl' of nuclear: damage associated with some nuclear enterprise could be declared acceptable if the sur total of the various f $\\ l i,' 3

-3. u T 1 t. u; ~,.1

i Te A

q, 6 i h,e. ii): A-peak to average risk: ratio of' 50 -shal)' not-be exceed-4' t ed. - (NOTE:* this - 'impli es a peak' individual risk limit gf 5 x 10-6 deaths / person-year) c& [ ii) The. average annual mortclity risk resulting from acci- + dent situations shall not ' exceed 10-B deaths / person-1 year. . 1-pt iv) A-bias ;against large accidents shal1~ be ef fec: ed by a (dw i E' Gimiting frequency vs magnitude relationship such that s ( Fr equency) = Constant x' (Magnitude)-l. 5,< 4 a- '(NOTE: in this context " Frequency" t.eans the total frequency of all events having consequences of similar

s cagnitude i.e. within e small magnitude bandwidth.

- 7n e P f'requency density ' f unction we use, namely dF : = AN dN,3 frequency and N is home measure of the.aonse- .where F = quences e.g. casualties, provides,an adequate model of the data. Integrated over a small range - say from K = n the sol ution approximates to to N =. n+1 [T f

• An[ provided n is large compared to 1) n n-Consideration of dispersion data indicated that the popul a- -

' tion at risk should normally be taken as that within 50km of s 1 the ssite but it was-noted that this might vary in particular sites with abnortal dispersion phenomena.' ~ 4 7no. f a: tor of 10- introSuced to lower the average accidental rish'e:andard was designed to allow for errors and omi$siens. in the identification and analysis of potential accident situations. E It was else noted - and licencees were so advised - that the w data supporting the bias index of -1.5 was more limited and less precise than the general data relating to average risks and that local violations of this bias limit line might be \\. ..,..,a

4- ~ o. pera.itted if the assessment of average accident risk showed a good margin of safety. Occupational Risks, i) Tne average annual mortality risk resulting f rot normal operation shall not exceed 2 x 10-4 dea ths 'per s on-- year. ii) A peak to everage risk ratio of 5 shall not be exceeded (NOTE: this impli e s a peak individual risk limit of la-3 dea ths / pe r s on-y e a r ) iii) The average annual mortality risk resulting frc: acci-dent situations shall n0t exceed 10-5 dea ths ' per son-year. iv) A bias against large accidents shall be effected by a limiting frequency vs magnitude relationship sa:h that ( Ma g n i t uf. e ) ~ 1. 5, (Trequency) = Constant x 3. Derived Release Criteria for Particular Sites Workir.g from the standards att out in 2 above it is car currer.: practice to provide prospective licensees with derived release criteria for each npecific sita. '. r. deci-ding or how these criteria should be deterrined. it o.s ori-g a r.e.113 broadly envisaged that tv.e principa: contributors to t.t e nc lear hazard would be nuclear power ntations, that i r. the l e r.g terr these would be distributed etre or less uni-f orr.l y over the country and that the spacing of e r.e plar.t fror e.nother would probably be such that there wru) d be little influence fror one station on the po; 'atien sur-roundir.g another. It was also assumed that po;;1ation distributions around the sites would probably be broadly similar and that the maximum int'.alled cepacities of the various sites would also probably be similar. Usir.g this broad-trush thinking the derived criteria for each site Qq[ ' "y j,% ' ', [% M ' [ I j) [..j

o m 4 pq ;.x % i h., Q# -couldi be{ established wi thout - consideration; of the of f acts.~of j ( any.other? site. J, 7 For each specific site it-is assumed that some form of acci- - dent can take place which will release.the entire ir. vent or y o~ ' of-nuclear hazard material onathe site, for' dispersion over $~ the'* population at risk". Using ' specific dispersion ' data-for the area and the forecast population' distribution at~the $,o end of plant life, and using the co-ef ficient recommended by s the J ORP' for converting the population exposure levels to

• • L

. o corresponding expected numbers of casualties,'it is possible to assign both-normal operation and ' accidental release i criteria to the site in ' que'stion, which are consistent with -the national standards laid d own. Certain approxications t 3 t = 'in volved - in this mathematical

process, namely the Q

are l' weather is broken. up into 6' categories only instead of being treated as a continuous probabilistic spectrum and the '1CRP. f co-etficient' is treated as a finite number whereas ir, actual s y t fact i-is only a "most probable" figure with a distribution h. I iaroun:,at. i 0-b '4;= Some Problems that have arisen in the App 1dcatioris, of the . Standards 4 - i .k O 4 i '4.1 -Maxitu: Accident 4 C onsecuences .\\: =r. i '4. 1 1-3 j' gyj. p The as ru:tption of an exact figure for the ec-efficient used 1 i ! A j tc cenvert. population dose te casualties leads' to 4the. .] k impression of.a fixed taxi:um number of' casualties ir. the j\\ c popula. ion at risk' f ror the worst conceivable accident;ir. B which.he total fission product inventory ir released. I r. ,61 <, ~ 3 (w%- s fact tr.e. co-e f f i c i e n t' represents only the "most probable * , s E~t-result and there are finite chances ' of both' g'reater.and t s ms 1 1 } 1 esse: consequences. Furthermore, at the present. time, we ~ ( do.not have evidence - to prove tha t -the.te is any dose 1 1 evel ' [' belos which damage will not occur or below which recovery i' k g;will a?.waps take place. Consequently we assurN 'that the \\ -\\ m dose-e f f ect relationship continues. linearly all the way down' 4 1 3Y ko to zer: dose. Workine within these assunptions we ma,tt aisc + <W. m,t, \\' '= k d kf 6 , 3%o 1 o p% W-m AM a. 3' "k

O 0 e ^ then admit that even one photon must have some

finite, albeit exceedingly small possibility of causing a lethal cancer.

Since a significant nuclear accident will always g give rise to many more photons than there are people in the area Affected, there must be some finite, albeit exceeding-ly small chance, that everybody can be killed. In practice the peakiness of the distribution around the "most probable" point ensures that so far as the risks are concerned, the adoption of a single figure will not und ul y distort the perspective, but it does tend to t empt licensees and other proponents of nuclear energy into making categorical state-ments regarding the abs ol u t e m a x im um number of casualties k-that can arise statements which cannot be rigorously defended. Since in most practical cases the adoptior of the most probable co-e f f i ci ent shows that the resul ting casual-l ties will only be a small fraction of the population at risk, there is often a wide discrepancy between the claims of the proponents and the cou n t e r-cl a im s of the:r oppe-nents. 1 : E We bel : cve, therefore, that it would be appropriate if our standards and the application of them could be seer to be a taking e proper account of even the remote possibilities associated with the conservative assumptions thet we have g adopted. d'f-4.2 Populat:or at risk-1; in m? There ;s an approximation in the definition and use of the I phrase popul a t i on at risk". Kr.ilst, for pTact :41 pur- [ f poses, t h e-cutoff point at sore 50 kr or

1. o f ror ar :. n s t a l -

latior ensures thet beyond that point contributio.s to the ] assesstent of total risk to the nation are o e. t. l l and ce.n be {

ignored, the 4isks, however stall, do nevertheless extend

~ 7 ^ further out and it is felt that a liritation of protection g I Ghould not be impl i ed by the wording of the utandardn, ,i 1 Rather let us allow the dhta and calculations tssociated l with ar,- particular site to determine the area that needs to

I i

be take* into account to give e s.ifficiently B C C i".T C t 6 f 4,.. n, _ _. _ m~ e a,a e m w w m y p y g m y-o p_ampgm a

~) assessment. Th e popul htion a t risk so far as the fanetion of the reg ulatory bcr$y is conc e r ned, should be the entire population over which its authority as exercised, i.e. the whole of the state. 4.3 Peak individual risks, average risks and peak-tp-a verage, risk ration The pe ak -t o-a v e r a g e risk ratio was introduced to reflect an observed societal tendency to lin.it the variation of i posed risk between different individuals within an area of regular social mobility and cont a ct. Where the nature of the popul a t i on distribution within the area of the sc called " pop u.l a t i on at risk" is f or t ui tousl y compa t ibl e wfth the application of the s t e.n d a r d s (as is the case at M:eberg) everything is fine. However, for less typical sitet, e.g. Go u r i g..a, the probler of meeting three limits, nacely peak individual

risk, a v e r e.g e risk and peak - t o-a ve r a ry:

risk ratio, can produce severe and unnecessary constrair.ts wh e r, the areas over wh. ch the f ig u r es must appl y are screwhtt arbitrarily d e f i r.e d. Tn e three factors should really be treated s epa r a t el y. The peak individual risk limit should apply to the individual at highest risk. Tn e peak t e-taerage r i sk Tatio lizit should apply within regions of regt.ar s o c.'. a 1 robility and contect. The averare risk lirit should ge nerally anply tc the natior, as a wh c.' e. If the geographic ar? demogrephic rature of a natior, were such that there were severa; pop ul e.t i on legions s e pa r e.t ed by large unp:>p.: lated a.reas, it right be appropriate t: treat the ratior nr a teriet of s u b-m e t i on s f o r. the purpcse Of applyir.g the ave: ape risk standards. 4.4 A c c i d.er Tt ien se r:ri tere h g ^ 1t han buen the c r e c t '. e:e to apply factors of sa f ety wher d l i,: sottiny a.vurege rick star.di.7dr for accident situations in 'j c 7, compar i sor. wi tn those set for r.ormal operatica, t o a l :. o w for s an a n t.m ed gretter degree of uncertain':y 'n f.h e data and ca ulen ons asucieted with the a c ci d e r. t assessmer:s. Ir, .ip j

.g. g 4_ s a / ~ the light _ of" experience it fis f elt that~-the standard should j-not ' pre-suppose-- a fixed degree of uncertainty. and ' apply. i t t,-. c indiscriminately to all; plants. The accident analysis asser i ciated with a uranium store,- for ex ample, will not carry anything -like the degree of uncertainty of an accident ana- ~ lysis, associated with.a nuclear power station. It is felt, therefore, that the same average risk standard shoul'd apply [ to both -normal operation and accident situations and that the appropriate margins for uncertainty should rather be g:% incorporated _in the assessment calculations, 7j 7t; With regard to the bias against larger accidents it was I noted in 2 above that the data supporting the index of -1,5, r ( selected back in 1970, was not very precise and, indeed, f some other number between -1 and -2 might equally well have f been selected. There was some evidence to suggest that at the very large accident end of the spectrum an index of -2 might well. be more appropriate. In more recent years other Jworkers -in the field have opted for an index of -2 and at e least-one werker has proposed dif f erent indices for the lar-i; ger and smaller accident ranges. Taking note of the point made.in 4.1 above, it was felt that the implications of our accident criteria on the acceptable limits for accidents in- .v olving a significant proportion of the total population . should..be investigated (even though the actual probability of such an event in association with a real plant would be p likely: te be negligibly stall) - and that this might throw some light on whether sore adjustment in the slope should be b made. There is growing evidence to suggest that the inci-gL.-. dence of cosmic. catastrophes capable of destroying a whole w -life species or genus may be in the range of 10-E to 10-9/ vear and it is felt that any criteria we adopt should at e. 3g least,be consistent with this. Integrating the frequency P AN dN, ' we show in fig ures 1 and 2 f gensity function dF = I the permissible integrated' frequency for all events result-j_ ing in n or more casualties where n is expressed as a pro- . portion of the c.otal population. Two values for index p, /. / -1,5 and ~2, have been used with the same average risk of o B 10 / deaths / person year applying in each case. For conve-rm .,k l / Y lY:YI y

~~~~ .9~ w:; y ; y,_ y J (( 4 nience thelplots-are made using-log scales. In table '1 are y.f f, shown, figures extracted from the curves for events involving-p E 50% -- and L more,,- 80% and mor e, and 90% and more casualties and also, for'a population of 60 million,.the figures for the two extremes, i'.e. total frequency of-all events involving 1-casualty _ and more, and total frequency 'of events in the range total population -1 to total population. If it'is accepted that-a catastrophe involving; more than-50% g' casualties represents the_ limit beyond which society will-be E unable to recover within a meaning f ul time scale, then-we believe.there is at least some evidence to suggest that if { we stay with a simple relationship with. a single bias index, it would be - more appropriate to use -2 than -1,5. 2-4.5 -Allocation of release criteria to particular sites Tae method of allocation currently used, as indicated.in 3 above, is satisf actory where the various sites have similar h plants with similar inventories and similar accident propen-sities. It' does, however, tend to ' introduce unreasonable E constraints when the different sites have different types of ~ plant-with different inventories and different accident pro-pensities. Bearing in mind _that our objective is, among other things, to limit' the average risks to the nation as-a whole and to; ensure that the summation of the accident pro-pensities of all. plants conforr. to the criteria for the bias

against larger accidents, it would be more appropriate if,

'in allocatine release criteria for particular sites, accour.t were taken of c-over when the risks presented by exist-the margin left ing plants have been deducted fror the total available risks allowable in terms of the national criteria, the particular size and nature of the plant to be =_ 7 e built on the site under consideration, and E the foreseeable need for future plants of different =

('

e

- loi. ~~ ~ y q-.- 3 i . types.'and natures being built on the same or - other 1 . sites-within the lifetime of existing plants.

A, properly' executed risk management policy of. this nature would be more economical' and less likely to exert unnecessary restraints on licensees.

5. Revised Standards Following from the considerations set out in 4 above it is proposed that the standards should be revised to' read ao ftllows: Population-Risks ? -The mortality risk to any -individual shall, not exceed 5 x 10-6 deaths / person year. Tne average annual mortality risk resulting from both normal operation and accidents shall not exceed.-10-7 ' deaths / person g, -year. Tnis limit shall apply to the. total. national popula-' s L . tion er.d. to such portions of the total population; as may?be L deem ~ed appropriate'in the light of demographic data. -l A' bias-against larger accidents shall be effected by a 1 lir.itir.g f requency vs magnitude relationship -of the form -2 AN = y dN in where F frequency of events = magnitude of consequences N = H and Al is a constant. A peak to average risk ratio of 50 shall not be exceeded in cora. unities or regions within which there a s regular social-mobility and contact. l'

g,..,. >

s..

g ~ Occupational Risks The mortality risk to any individual shall not exceed 10-3 d eaths.'per son year. The average annual mortality risk resulting fror. both normal operation and accidents shall not exceed 2'x 10-4 deaths / person year.. A bias against larger accidents shall ' be effected by a limiting frequency vs_ magnitude relationship of the form = A pN -2 dN 1 l A peak to average risk ratio limit of 5 shall. apply to thd radiation workers'at_e'particular site and/or to such subdi-visions of this work f orce as may be deer.ed appropriate. f t' l 6. Application of the Standards f It is proposed that the standards should be applied in accordance with the' risk management policy referred to in 4.5 abeve. Fo ea:h new licence ' application recom..endations regarding J site specific criteria together with supporting-inforcation 'will be submitted to the Council for Nuclear Safety for con-s id era-ion. The Council ' s findings will then be forwarded '~ to the:AE0 as in the past. Notwithstanding the limits laid dowr., as in the past the licensee. will be required, in t e rr.s of the licence, to reduce the actual risks as far below the limits as is reasonably achievable. 4 It should be noted that the changes to the standards are small and that the criteria already applied to Koeberg in terms of the licence are compa tible with the revised stan-dards.

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,.s,. p 1.' g -'-. ,f^ 4 y /.- - NATIONAL RISK CRITERIA ~ F ItG. 2, SWi" J. E-POPULATION RISK Fr e q uenew-Masyn i tude Curves. ~ l

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l#~ TABLE 1: XATIOXAL CRITERIA =_ FREQUEXCY-MAGNITE DE LIMITS ll gr { FREQUENCY OF EVENTS IIIAS INDEX l PER YEAR IXCLUDING -1.5 r?.0 i I i A ND GREATER TllAN:- TOTAL POPULATION -1 8.3 E-16 9.:t E-17 90% ~0F POPULATION 5.4E-09 6.:3 E--10 E 80% OF POPULATION 1.2E-08 1.4 E-4)O 50% OF POPULATION 4.1 E-08 5.6 E--O U J 1 CASUALTY 2.3 E-04 1.7E-01 = _ - = _ .v=- =. - _ _}}