2) Relatório apresentado por Portugal no 6º Review Meeting da Convenção de Segurança Nuclear
Eventos e presença internacional
1) Apresentação da CORMSIN em 25 de Março de 2014 no Agência Internacional de Energia Atómica.
3) Sessão de perguntas e respostas de vários países relativamente ao relatório apresentado pela COMRSIN.
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Australia
1) It is applauded that “…for the first time in Portugal to the existence of an independent regulatory body for nuclear safety.
We thank Australia for the comment. We feel we have a long way to go until we are able to fulfill all our duties as expected. However, it is clear that Portugal, in this matter, began a one way journey and has reached the point of no return.
2) Additional information regarding processes and systems for detecting and reporting incidents would be useful.
The operator has extensive check lists for all systems and components. There are operator obligations on reporting for the Safety Commission and for the regulatory body (COMRSIN). The operator participates in several discussion fora, such as the Research Reactor Operators Group (RROG) of the European Atomic Energy Society and the Incident Reporting System for Research Reactors of the IAEA.
3) The term “exploration” is used throughout the report. Is it possible this is a miss-translation and should be “exploitation” or “use”?
You are correct; the proper word is “exploitation”.
USA
1) In Article 8, you state that COMRSIN does not yet have the financial, technical and legal resources that are needed to make it an effective regulatory body. COMRSIN is supposed to take over regulatory responsibilities in mid-December 2013. What steps have been taken to address these difficulties?
This is a key issue that constitutes major concern to us. Since the creation of COMRSIN as a regulatory body we have been overwhelmed by the transposition of EU legislation and the participation in international forum such as IAEA, OECD and ENSREG. Only three commissioners were appointed and no supporting technical staff has been granted on a full time basis so far. Due to the ongoing financial crisis, and under strong limitations imposed by Troika (IMF/ECB/EC), the government in 2012 precluded creating an additional body with full financial and administrative independence, but instead gave COMRSIN access to ministerial administrative staff members and a budget within that same ministerial body, the Secretaria Geral do Ministério de Educação. Recently, the government promised, in DL 156/2013 of November 5th, to restructure COMRSIN in a way that cures some of the shortcomings. In the mean time COMRSIN has been given an administrative assistant with some experience in EU business matters, and two part time assistants: one in public relations and secretary to handle logistics. There is no adequate technical and legal support yet due to budget restrictions.
Germany
1) It is stated that each facility must prepare internal emergency plans and periodically test them according to the conditions set out in the licenses of the respective facilities or installations. Do these plans have to be updated periodically?
Yes. It is the duty of the operator to test emergency plans every year and update them when needed or after an actual emergency.
2) We highly appreciate the establishment of the regulatory body. This is an important step to implement the CNS-obligations.
We thank Germany for the comment. We feel we have a long way to go until we are able to fulfill all our duties as expected. However, it is clear that Portugal, in this matter, began a one way journey and reached the point of no return.
Japan
1) Licensing of the RPI:In this 6th national report, it is described that a safety analysis report on the core conversion was prepared based on the IAEA safety recommendations. In the 5th national report, it is described that the safety analysis report was prepared by the United States (ANL), reviewed by France (IRSN), and the final appreciation was made by IAEA.
The 5th national report stated the following:“The conversion was done by the operator of the RPI under IAEA´s TechnicalCooperation Project POR/4/016, with assistance of an independent expert of France (IRSN) and a research center in the United States (Argonne National Laboratory ANL). In the framework of the core conversion and the reactor licensing, the RPI underwent a thorough safety analysis. A Safety Analysis Report was prepared, based on the IAEA safety recommendations (e.g. the Safety publication: Safety Series Nr. 35-G1, “Safety Assessment of Research Reactors and Preparation of the Safety Analysis Report”, as well as the “IAEA Research Reactor Core Conversion Guidebook” TecDoc 643). In this context, a safety analysis for the core conversion was performed by ANL, and a review of this report was prepared by an independent expert of the IRSN, based on IAEA Safety Standards NS-R-4, for final appreciation by the IAEA. Additionally, ITN prepared an analysis of “site characteristics”, including an estimation of the RPI’s gaseous and liquid effluents, as well as a report on the radiological safety in the RPI.”At that time there was no regulatory body in Portugal as it is required in the CNS. We remind Japan that the Portuguese Regulatory Authority has been created in March 2012. In 2007 the license was issued by the General Directorate of Energy and Geology.Given the fact that the specialized resources necessary to evaluate these topics were all in the operator, the Portuguese competent authority in 2007, the General Directorate for Energy and Geology, needed support from foreign institutions to validate the information.
2) Assessment of the safety of the RPI: In page 17 of 5th national report, it is described that a safety analysis has to be performed by the reactor operator. In the bottom lines in the page 18 of the 6th national report, it is described that the RPI must have a Safety Analysis Report, which will be subject to validation by COMRSIN after December 17th 2013. And this report is required to be updated whenever necessary or if requested by COMRSIN.
Right now there is no international involvement in the preparation of the safety analyses report by the operator. The safety analyses report was prepared by the operator. It incorporated data supplied by the original manufacturer of the reactor in the late 1950s, data from operational experience and the latest safety studies. The operator submitted a new version of the safety analyses report to COMRSIN in December 2013 within the scope of the Decree-Law 262/2012, which is currently being evaluated.
3) The Report says that the renewal of the RPI in 2015 will be up to the COMRSIN to analyze and decide. Will this renewal be carried out due to expiration of the valid date of the license, or will be carried out according to Decree- Law 262/2012? And, how long is the valid term of the license of the renewal?
The license issued by General Directorate for Energy and Geology is still valid for the current fuel, whose use will cease in May 2016. COMRSIN is now reviewing the support documents, in order to verify the compliance of the operator to the new safety requirements established by the Decree-Law 262/2012, which complete the transposition of the EURATOM nuclear safety Directive. Under the article 40(1) of the Decree-Law 262/2012, in the end of the analysis COMRSIN will issue a certification that confirms if the operator is complying the safety requirements of this law.The operator himself has not decided yet if it wants to continue operation of the RPI beyond 2016 given that there is a time frame to return the fuel of the RPI to the US under the same program the lead to the conversion of the core to low enriched uranium.
How is the organization chart of the Regulatory Commission for the Safety of Nuclear Installations (COMRSIN), and how many staffs are there in the COMRSIN?
COMRSIN has only three appointed commissioners and no staff members of its own, given the budget limitation that existed at the time of creation in 2012 due to the serious financial crisis and the presence of the Troika (IMF/ECB/EC) scrutinizing all acts of government. The outcome of such scrutiny lead the government in 2012 to preclude creating an additional body with full financial and administrative independence, but instead gave COMRSIN access to ministerial staff members and a budget within that same ministerial body, the Secretaria Geral do Ministério de Educação. Recently the government promised, in DL 156/2013 of November 5th, to restructure COMRSIN in a way that cures some of the shortcomings. In the mean time COMRSIN has been given an administrative assistant with some experience EU business matters, and two part time assistants: one in public relations and secretary to handle logistics. There is no adequate technical and legal support yet due to budget restrictions.
Brazil
1) Are the national emergency plans tested for possible national events involving radiation sources? How often are national emergency exercises performed?
There is no periodicity on national emergency exercises. They are done in coordination with Europe or within the Iberian Peninsula. COMRSIN participated in Spain, in the fall of 2013, in Curiex 2013, an exercise promoted by CSN.The national emergency plans are tested by the National Authority for Civil Protection. The last exercise which involved radioactive sources was made in November 2013. This exercise was connected with the IAEA exercise CONVEX 3.
2) It is stated that COMRSIN is managed by 3 commissioners, but nothing is said about technical staff. Is there a permanent staff working for COMRSIN? If yes, how many people and what are their qualification and organization? If not, how is COMRSIN performing its duties related to assessment and inspection?
Due to the ongoing serious financial crisis the government in 2012 precluded creating an additional body with full financial and administrative independence, but instead gave COMRSIN access to ministerial staff members and a budget within that same ministerial body, the Secretaria Geral do Ministério de Educação. Recently the government promised in DL 156/2013 of November 5th to restructure COMRSIN in a way that cures some of the shortcomings. In the mean time COMRSIN has been given an administrative assistant with some experience EU business matters, and two part time assistants: one in public relations and secretary to handle logistics. There is no adequate technical and legal support yet due to budget restrictions.Therefore, to assess and inspect the RPI in the near future COMRSIN may reach out for international help in order to overcome the lack of technical experts that are both independent from the operator and part of the regulatory body. Portugal has all its technical expertise in nuclear reactors and irradiated fuel at the RPI; therefore at the moment, to avoid conflict of interest COMRSIN may have to reach out for international support in case it needs additional expertise.
3) The effort of Portugal to transpose EU directives in its legislation is commendable.
Thank you Brazil for your comment.
