Comments on the ICRP draft document Radiological Protection in Surface and Near-Surface Disposal of Solid Radioactive Waste
Background of ARPANSA
ARPANSA is the Australian Government’s primary authority on radiation protection and nuclear safety. A component of our purpose is to regulate Commonwealth entities and to promote national uniformity in the approach to regulation in Australia. While the enforcement of regulation concerning radioactive waste disposal is undertaken by the Commonwealth, State and Territory regulators in Australia. ARPANSA leads the introduction of international best practices into the Australian regulatory environment through its role in the development and publication of national radiation protection standards, which is done in consultation and collaboration with all jurisdictions of Australia. Furthermore, ARPANSA acts as an expert advisory resource for State and Territory bodies. In these roles, ARPANSA regularly draws on the recommendations of the International Commission of Radiological Protection (ICRP) along with safety standards and guides produced by the International Atomic Energy Agency (IAEA), and so has a vested interest that guidance at the international level is consistent and implementable.
General comments
ARPANSA is grateful for the attention taken in addressing this topic. The development of surface and near-surface waste repositories is an issue of great interest in the present Australian regulatory environment, given the ongoing efforts to establish a National Radioactive Waste Management Facility for near-surface low-level waste disposal.
On review of the present document, it is evident that great care was taken in the preparation of this draft, and ARPANSA is broadly satisfied with both the general content and direction of the document. The application of both the three fundamental principles and four core ethical values provides a cogent and informative framework for approaching the challenges of near-surface waste disposal, and the publication furthermore provides a good overview of the issues and challenges that must be considered in this space. ARPANSA commends the ICRP on a thorough and clear document. That said, it is felt some suggestions that may improve the document further; to this end one general comment is made and additionally a small number of minor comments are identified below as potential areas for improvement.
Graded approach
ARPANSA notes that the concept of a graded approach is an important aspect of the international guidance on the handling of radiological materials, being outlined as a general safety requirement in IAEA’s General Safety Requirements Part 3 Protection against Ionizing Radiation and for the Safety of Radiation Sources: International Basic Safety Standards. It has likewise been discussed in prior ICRP documents, for example ICRP Publications 103 and 126. Despite this, the graded approach is not discussed within the present document and how it is applied in the system of radiological protection to near-surface disposal of radioactive waste and to the implementation of the system of radiological protection to the phases of a near-surface disposal facility for radioactive waste. This concept is a useful framework for considering and mitigating the way in which people and the environment may be exposed to radiological hazards by ensuring controls are appropriate to the level of risk. Notably, the concept of graded approach intersects the listed principles of optimisation and dose limitation as well as the ethical value of prudence used to guide this document’s creation; the discussion of these topics could therefore serve as a good location to include discussion of this approach. ARPANSA recommends its inclusion in the present document as it is embedded across the ICRP recommendations and IAEA standards.
Specific comments
Pages 6 and 9, Figs. 1 and 2: Figure captions use title case for these two figures, but sentence case for all other figure captions. Suggest changing this to be uniform throughout the document.
Page 8, paragraph 15, line 273: “This depth range is not indicative only”. Is the “not” before the “indicative” intended?
Page 12, Fig. 3: This figure needs additional work, as the figure is neither clear nor aids in explaining the concept of isolation. Suggestions for improvement include:
- Change wording of isolation arrows to something more descriptive than "isolation" e.g. "Siting away from population/environment", "Depth"
- Redraw the figure to show and label some other aspects of isolation beyond just distance, such as those outlined in paragraph 26. E.g. show fences/gates for "access control", show restriction of grazing cattle for "land use control", highlight other examples of "design to minimize the influence of factors..."
Page 14, Fig. 4. This figure shows activities required for the successful establishment, operation, and shuttering of a near-surface facility, but neglects to address gaining regulatory approval through the preparation and regulatory assessment of a safety case. While areas of regulatory control may be somewhat touched upon under the “related protection activities” shown in later phases, these are only partial overlaps, and it is outright not covered in the pre-operational phase of the figure. The only somewhat related extant activities listed in this phase are siting and design, which must be considered separate from the regulatory approval. This difference can be noted in international guidance; for instance, Requirement 12 of the IAEA SSR-5 is the “Preparation, approval and use of the safety case and safety assessment for a disposal facility”, which notes:
A facility specific safety case has to be prepared early in the development of a disposal facility to provide a basis for licensing decisions and to guide activities in research and development, site selection and evaluation and design. The safety case has to be developed progressively and elaborated as the project proceeds. It has to be presented to the regulatory body at each step in the development of the disposal facility.
Here it can be seen that this regulatory aspect feeds into both siting and design decisions, and evolves in concert with them, but is a distinct activity. Therefore, the inclusion of discussion relating to regulatory approval here would thus bring this figure into better alignment with IAEA guidance, as well as discussion later in the current document (e.g. paragraphs 94, 101). Paragraph 32 should be updated to reflect this change, as well.
Page 30, paragraph 99, line 1170: “The safety case would exam these issues”. Change exam to examine.
Page 31, paragraph 102, line 1198: Suggest removing hyphens in “defence-in-depth” to align with usage of phrase in other parts of document (e.g. lines 85, 564).
Page 36, paragraph 124, lines 1427 to 1430: While ARPANSA agrees with the ICRP that it is out of scope to discuss the protection of a deliberate intruder, we believe it is worthwhile to consider the possible negative impact a deliberate intrusion may have on others beside the intruder. ARPANSA’s stated view on this topic as expressed in RPS C-3 Code for Disposal Facilities for Solid Radioactive Waste is that:
Deliberate intrusion may also arise from malicious intent. The concern here is with the safety of those indirectly affected by the intrusion. The arrangements for institutional control including security should reduce the worker, public and environmental risks associated with such intrusion to the level as low as reasonably achievable.
Comment