Nuclear power is often in the headlines as a potential source of energy for South Africa. The debate on the safety of nuclear installations and how it affects the environment and the impact upon those living nearby is one that constantly makes the front pages in the media.
What many are unaware of, is the fact that South Africa has an independent National Nuclear Regulator (NNR), which is mandated to ensure that standards pertaining to any nuclear installation or development of nuclear technologies comply with the strictest and most stringent of national and international safety standards.
The nuclear industry, though small, is highly technical and specialised. It encompasses power generation, mining, medical, nuclear waste and transportation, all of which have an impact upon industrial players, workers and civil society. It is with this in mind that the South African Government established and mandated the NNR to oversee and implement safety standards for the nuclear industry through the National Nuclear Regulatory Act of 1999, which is administered by the Minister of Energy through the Department of Energy. This enables the NNR to enforce safety standards required for the successful and safe operation and usage of nuclear materials and plant.
The National Nuclear Regulator
The NNR is mandated as the competent authority in terms of the National Nuclear Regulator Act, 1999 (Act 47 of 1999) for ensuring that individuals, society and the environment are adequately protected against radiological hazards associated with the use of nuclear technology in South Africa.
A key priority for the NNR is to develop and maintain an effective and efficient national regulatory framework for the protection of persons, property and the environment against nuclear damage.
In addition, the NNR advises the Minister of Energy on matters falling within the Ministry's purview; fulfills national obligations in respect of inter- national legal instruments concerning nuclear safety; and Acts as the national competent authority in connection with the International Atomic Energy Agency's Regulations for the Safe Transport of Radioactive Material.
Some of the key aims of the NNR are: to establish safety standards and regulatory practices; to exercise regulatory control over nuclear installations, vessels and any other action capable of causing nuclear damage, to which the NNR Act applies; through granting of nuclear authorizations; to provide assurance of compliance to conditions of nuclear authorisations; and to ensure that provisions for nuclear emergency planning are in place.
In order to ensure effective regulatory control the NNR develops and implements regulatory standards and practices that are benchmarked with internationally accepted principles.
The NNR currently regulates: the Koeberg nuclear power station, nuclear installations on Necsa' Pelindaba site, Vaalputs national radioactive waste repository, several mining and mineral processing facilities, and the authorization of vessels either propelled by nuclear power of carrying radioactive material. The NNR issues nuclear authorizations in the form of: Nuclear Installation Licences; Nuclear Vessel Licences; Certificates of Registration and Certificates of Exemption.
To give effect to the principles of cooperative government and inter-governmental relations as contemplated in the Constitution of the Republic of South Africa, the NNR has concluded cooperative governance agreements with the Department of Energy; Department of Health (Directorate Radiation Control); Department of Minerals Regulation; Department of Water and Environment Affairs; Department of Transport (Civil Aviation Authority, Railways Safety Regulator, Road Transport Management Corporation, South African Maritime Safety Authority), and the Department of Labour.
The NNR has close ties with the International Atomic Energy Agency (IAEA), a United Nations body for the peaceful use of nuclear energy and South Africa is one of their 130 member states. The IAEA has been in force since 1957 and is regarded as the world's foremost international agency for scientific and technical co-operation in the peaceful use of nuclear energy.
Officers of the NNR participate extensively in the IAEA Safety Committees, conferences, programmes and workshops as part of their ‘global up skilling initiatives' that ensures that they are exposed to the latest thoughts and technologies relevant to the safe operation of nuclear establishments. The NNR also participates jointly with the IAEA, upon request, in overseeing nuclear submissions from other countries and the implementation thereof as part of their constant re-education and best practice initiatives.
The NNR also has bilateral agreements with ASN, the French Regulator, CNSC Canadian Nuclear Safety Commission, USNRC and the UK, Health and Safety Inspectorate. The NNR also has co- operation agreements with other participants in the Multinational Design Evaluation Programme (MDEP) which brings together regulators of ten countries facing similar challenges in terms of licensing new reactor designs.
With the country's growing energy requirements regularly under the microscope, the nuclear power, option as part of the energy generating mix is a consideration, for the South African government - this presents the NNR with the challenge of ensuring that any new nuclear power station commissioned is in the first instance safe for the workers and that the communities which live nearby are not only protected but are also constantly updated and informed of safety aspects pertinent to their environment. This is regarded as a high priority for the NNR.
The NNR, based in Centurion, has a small yet high-powered and passionate team of experienced technical experts that oversee the implementation of nuclear standards and requirements in South Africa. Their function is to review and assess nuclear proposals of any such undertaking by ensuring that submissions comply with South African nuclear standards and guidelines, which are internationally aligned. The team comprises of inspectors, engineers, scientists and technical specialists and appropriate support staff.
"South Africa has more than 20 years experience of safe nuclear power plant operation and experience in research, development and use of nuclear related technology. In the government's vision for the development of an extensive nuclear energy programme, the NNR will play a vital role as the competent authority responsible for licensing new-builds for the future." says NNR chief technical officer Mnonoki Msebenzi, who is responsible to ensure that the NNR is able to respond to the envisaged challenges posed by a new build programme, besides others.
The NNR embarks on a series of forward planning activities and one such activity is developing a robust licensing framework for the new build programme. The licensing framework can be broken down into four partially overlapping phases, although in some instances the licensing process can accommodate combined phases.
Licence application to site a nuclear installation
The NNR reviews the application to site a nuclear installation. This phase of the licensing framework must address the suitability of the site for nuclear installations against the nuclear safety requirements. Provisions for public participation hearings are included in the licensing framework for the siting of new builds.
Preparatory phase prior to application for licence for the construction and operation of nuclear installation
This phase can be considered as a pre- licensing phase during which the NNR will need to prepare itself in terms of planning, staffing, training and familiarization on the relevant technologies being considered by the applicant, identification of any long term licensing issues, and securing external technical support as may be required.
Review of the application for the construction and operation of a nuclear installation
Regulatory activities following an application for a nuclear installation licence for the construction and operation of a nuclear installation, including the public participation process. This is the most important phase which includes a detailed NNR review of the safety case presented by the applicant to demonstrate that the nuclear installation will comply with the NNR safety requirements and culminate in the compilation of the NNR Safety Evaluation Report which would guide the decision process for issuing (or refusing) the nuclear licence for construction.
NNR Board review and decision process
Following the submission of the final Safety Evaluation Report to the NNR Board, and consideration of the outcome of the public participation process, the Board would direct the CEO to grant (or refuse) the nuclear installation licence.
Subsequent licence stages:
Should the licence be issued for construction, the licensing process will continue for other phases such as commissioning up to the operational phase. For each phase the NNR will require a safety case demonstrating that the installation meets the NNR regulatory requirements and the licence will be updated accordingly, says Msebenzi.
"One of the biggest challenges for the technical experts of NNR in conducting their review and assessment of submissions from applicants or holders of nuclear authorisations, was one of 'are we going far enough in our review, assessment and decision making to ensure the safety of nuclear operations in terms of breadth and depth of safety? As a regulator are we doing enough?' As a regulator we have obligations to the international community in addition to our local responsibilities, as a nuclear accident in South Africa is a nuclear accident worldwide meaning that a nuclear accident anywhere in the world would have serious implications on the rest of the world. Thankfully, South Africa has had no such accident in its nuclear history, which is an extremely positive reflection of how we manage and maintain standards and safety requirements for such operations," says NNR senior manager: technical division Guy Clapisson.
"The NNR has established its credibility through its positive track record and its ability to regulate and assess submissions with appropriateness and expertise. The NNR is currently active in regard to environmental related issues related to mining operations. South Africa has a National Nuclear Energy Policy which amongst others provides some guidelines linked to the value added of the beneficiation process of uranium ore and the implementation of a strong nuclear energy programme such as and the expansion of the whole nuclear fuel cycle in the country," he says.
With a professional qualification in nuclear engineering, Orion Phillips, is the Senior Manager responsible for the regulation of Necsa activities at Pelindaba including and radioactive waste manage- ment at Vaalputs. He is also responsible for the regulation of facilities that handle Naturally Occurring Radioactive Material (NORM) in the country. He told Engineering News "One of the challenges facing us at the NNR is the protection of the environment from historical pollution emanating from mining activities, and currently, there is a requirement for the NNR to be actively involved in on-site characterization and to advise on the appro- priate standards required for a clean-up operations to be successfully implemented, and thereby ensuring optimum levels of safety".
"Our role with Necsa is to provide expert advice on safety standards for research reactors and nuclear fuel cycle applications. In terms of maintaining our independence, we may not promote the usage of nuclear power or research reactors in South Africa, but ensure that such installations and plant conform to the best safety standards possible. The NNR has, and will continue to demonstrate its competence in nuclear and radiation safety to the public at large and to create awareness about averting nuclear damage in the public domain. The NNR is not only the nuclear safety watchdog but has to engage proactively on such issues" he said.
The exposure of workers and the public to the ionizing radiation produced by radioactive waste could have serious health issues, it is due to this risk that the NNR carefully controls and regulates nuclear waste. The regulatory process considers health risks upon the current population of South Africa, as well as the impact upon future generations.
Necsa is responsible for the management and operation of the national Radioactive Waste Disposal Facility at Vaalputs, and does so through compliance with NNR authorisations and safety requirements.
"Reporting on compliance assurance through performance inspections and audits as well as investigations with authorised licence holders ensures that we at the NNR are kept abreast of the positives and the negatives in terms of nuclear technology and waste management at the licencees site " says Avinash Singh, Senior Regulatory Officer at the NNR's Nuclear Technology and Waste Management Programme.
"A technical criterion for a successful submission would include compliance with the specific regulatory documents for example RD-0017: Basic Licensing Requirements for the Pebble Bed Modular Reactor (PBMR) Fuel Manufacturing Plant, or RD-0018: Basic Licensing Requirements for the PBMR Reactor, or RD-0034: Quality and Safety Requirements for Nuclear Installations. In the absence of a RD, then submissions would have to comply with international standards such as IAEA TS-R-1 Regulations for the Safe Transport of Radioactive Material if the submission was transport related".
"All authorised licencees need to inform the NNR of any modifications, setting changes or amendments which may have an impact on safety to the original proposal that was approved in the first instance. These changes, however big or small, still have to be approved by ourselves, as we carry the responsibility for overseeing that licencees conform to the required standards, and we will not compromise our integrity in this regard. We have a mandate to protect the public and the environment from radiation damage, and while the implementation of safety practices and processes rests with the licencee, it is our duty to keep abreast of international trends and to offer these as guidelines locally where applicable," Singh continues.
"Standards are not static, they get updated as new data and technologies evolve. We at the NNR are obliged to keep ourselves informed and familiar with all new or updated standards for the nuclear and nuclear waste sectors. When presented with a submission for the disposal of nuclear waste for example, the proposer will submit all details of application, implementation and safety processes for us to assess. Therefore it is crucial that we are abreast of new developments so that we can assess the submission correctly and authorise the submission and/or make recommendations for the proposer to include in his submission in order for it to find approval with the NNR," concludes Singh.
The NNR is the authority that outlines the nuclear waste transportation standards and requirements. Strict conditions are imposed on the transportation of nuclear waste materials and South Africa's NNR aligns itself to international nuclear waste transportation standards as laid down by the IAEA. While the NNR may issue the authorisation for nuclear and hazardous waste transportation, it is imperative that the holder of the nuclear authorization complies completely to the NNR stated requirements.
One of the highlights of Senior Specialist: Electrical Engineering Assessment Group Pelei Bernard Petlane's career at the NNR was working with Eskom Koeberg as part of the NNR and assessors team. "I went to the factory acceptance testing in Erlangen, Germany to witness the operational tests for the Reactor Control Rods system that was to be installed at Koeberg by AREVA. I was also on-site to check the installation that was to be replaced as well as witness the Simulator Operational tests on the new software for the Digital Reactor Control Rods system This helped me with wrapping-up the approval assessment for this system. This cradle to the grave experience was immensely satisfying and greatly assisted in my abilities to compile the final signed-off report on the project".
"One of the most critical requirements I look for in submissions to the NNR is the incorporation of safety related control systems, an aspect that all players need to remain up to speed with due to its ever-changing nature. With the advent of ever changing technologies within the nuclear sector locally and internationally, keeping up to date with the latest information and procedures and processes is one of the biggest challenges facing us at the NNR. If we are to guide players in the nuclear industries on the standards expected of them, we must conduct our research efficiently and effectively to be able to speak with authority - I believe we do this admirably and it is a never ending process," Petlane continues.
"A lot has changed, and one or two lessons have been well learned over the 23 year lifespan of the NNR. If we as the official regulatory institution tasked with safety standards in the nuclear fields become lax in any way in our knowledge then we open ourselves up to not only industry criticism but also to public criticism - and I believe we have sufficient integrity within the people of the NNR to not let this situation ever take place" he says.
What is nuclear damage? It is explained as an injury, death, sickness or disease of a person; loss of property and environmental damage as a result of ionizing radiation from nuclear installations or radioactive materials - Dr Margaret Mkhosi, Senior Specialist: Nuclear Engineering is a leading ‘accident analyst specialist' at the NNR.
Dr Mkhosi told Engineering News: "Every submission received by the NNR from the proposer must have a Safety Analysis Report contained within the documentation, to demonstrate to the NNR the systems the proposer has in place in the advent of a nuclear accident. The Safety Analysis Report has to contain procedures and strategies that answer questions like ‘how the will the nuclear fuel be cooled?' ‘how will radioactive materials be contained?' These procedures also have to address every possible nuclear accident condition, covering the very worst of events and address the operational conditions under which certain aspects will occur in a nuclear reactor in order to become authorised by the NNR ".
"Even when equipment in the nuclear reactor needs to be replaced, whether it be valves, electrical cabling, pumps or heat exchangers, these too have to be resubmitted for approval by the NNR prior to replacement, to ensure that the specified replacement equipment and materials comply with the standards laid down by the NNR - if they do not, the NNR will make suitable recommendations for standards to be met and the proposer will need to ensure that when resubmitting his submission for approval that replacement materials meet the recommended standards".
"We are fortunate that South Africa has an excellent nuclear track record and that key players and stakeholders are aware of the standards expectations and comply readily and proactively. All of us in this sector are acutely aware of the damage of a nuclear accident/spillage on people and the environment and I believe that we are all working from the same page - so that no such incident will arise and I am proud of that collaboration," Mkhosi says.
"Design of nuclear plant and its systems and structures is an integral component of radiation protection and nuclear safety" says Malcolm Europa, Principal Specialist, Mechanical Engineering for the NNR based in Cape Town " and it is my role, in conjunction with my colleagues, to assess the adequacy of measures taken or implemented by licencees or licence applicants".
"Obviously being based in Cape Town, Koeberg is my primary area of work and focus. I specifically look at the submissions for approval as to whether the standards employed are within the scope of South African law and whether they constitute best engineering practices. In addition, I seek to see if proposed mechanical engineering principles are applied in tandem with safety philosophies and that the end result is one of increased plant safety not decreased plant safety - that is a critical area of concern to me".
"The challenges facing the NNR are issues around what new nuclear tech- nologies may enter the South African realm in the future, in terms of potential new build especially if it is a reactor type not previously installed here for example a boiling water reactor, compared to the light water reactor as is Koeberg. This is where our international contacts and links with the IAEA and our global research associations would be important to enhance our current knowledge bank. The ability to research presented papers and documents of import via the Internet is invaluable to our NNR activities. It is a coup that the IAEA does enlist the support of South African reviewers on many of their technical documentations,- this in itself is a feather in the cap of the NNR and enhances our global relationships and knowledge gathering"
"I am currently representing the NNR on two technical committees of the Multinational Design Evaluation Project (MDEP) - an initiative which develops approaches to influence the resources and knowledge of the national regulatory authorities who will be undertaking the review of new reactor power plant designs in the near future. These are the Vendor Inspection Cooperation Working Group (VICWG) and I also collaborated on their Codes and Standards Committee where the similarities and differences among codes and standards for pressure boundary components were evaluated," Europa says.
Nuclear activity, operations and nuclear waste transportation within industry and our surrounds are not going to disappear. What is important is that nuclear and nuclear related activities are conducted in a safe and responsible manner and that industry players adhere to the standards and requirements advocated by the South African NNR completely. We believe that the NNR has impeccable credentials locally and internationally. We believe that the NNR is abreast of global nuclear trends and developments and is perfectly placed to assist South African industry, civil society and our environment to remain a safe, clean and a protected place for all.