Safety at Necsa
Safety, Health, Environment & Quality Digest March 2014 issue
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Safety, Health, Environment & Quality Digest July 2013 issue
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With the advancement of the utilization of nuclear power it is a given that we at Necsa regard nuclear safety of paramount importance. It is our responsibility to secure and protect people and the environment from potential damage.
That is why we have a specialised Risk Management division, dealing with across the board safety needs.
This division consists of several functional groups, each with their own field of expertise. All Risk Management focus groups also provide a single point contact function for official liaison with various external bodies.
The Professional Support Group is responsible for System Development, Operational Procedures and Project Evaluation and Approval.
These specialists are responsible for the development and maintenance of the NECSA HSE system. The HSE are safety policies, programmes and procedures and includes the EMS, conventional safety, radiological and chemical protection policy, systems and programmes.
The RP programme complies with international (e.g. IAEA and ICRP) and national regulatory standards and principles. The EMS is in compliance with the Nuclear Licence, the various environmental Acts and the ISO 14001 standard. The NECSA Nuclear Licencse stipulates policies and procedures for environmental monitoring, dose assessment to the public, Annual Authorised Discharge Quantities (AADQ) for liquid and gaseous releases, and emergency environmental monitoring.
Nuclear licence related activities:
- Establishing and review of the corporate environmental programme, policy and procedures. This includes policy and procedures for environmental monitoring, dose assessment to the public, Annual Authorised Discharge Quantities (AADQ) for liquid and gaseous releases and emergency environmental monitoring.
- Review of the environmental impact of new facilities, the non-compliance with licence conditions (from an environmental viewpoint) and annual environmental and meteorological reports.
- Determining the adequacy of the radiological and chemical protection programmes through evaluation of the workplace and personnel. This includes the monitoring of results and implementation of improvements where necessary.
- Providing a scientific support service to line management regarding the identification, measurement, evaluation and control of radiological and chemical hazards.
A comprehensive Emergency Plan is developed and maintained as an integrated part of the radiation control programme. The Emergency Plan deals with radiological and chemical emergencies. The plan makes provision for the evacuation of members of the public living within a 5 km radius of NECSA.
The Risk Management division liases with the NNR, Local Authority and Department of Labour with regard to emergency plan matters (radiological and chemical). The emergency plan also covers off-site effects of NECSA emergencies.
Operational Procedures and Project Evaluation and Approval
The Professional Support Group also provides specialist radiological and chemical protection consultation and general HSE support service during the design, fabrication, construction commissioning and operational phases of projects.
The group consists of Radiation Protection, Criticality Prevention and Transport Specialists who review and approve facility specific projects, procedures, calculations and modifications.
Other functions include:
- Providing an infrastructure for the training of radiation protection staff to supervise the radiological aspects of radiological tasks, including scientific guidance and control in order to assure the correct utilisation of nuclear instrumentation and monitoring systems.
- The development and presentation of training programmes to ensure proficiency of radiation protection personnel. Acceptance of workplace monitoring programmes to evaluate the radiological and chemical safety status in facilities.
- Assuring that gaseous effluent releases are evaluated using appropriate monitoring and measuring techniques and providing reports on the quantities released.
- Special investigations of chemical and RP related occurrences.
- Providing other radiological safety related functions such as:
- Review and acceptance of radiation protection procedures (including facility specific procedures),
- Environmental surveillance programmes
- Transport assessments
- Ventilation system assessments
- Radiological effluent assessments
- Meteorology programme requirements
- Shielding assessments
- Off-site consequence assessment
- Emergency planning
- Compliance audits
- RP instrumentation.
Medical Surveillance, Dosimetry and Records
This focus group is responsible for verifying, reviewing and performing specialised personnel exposure evaluations.
They also design and provide an administrative system for the registration and control of records of occupationally exposed persons.
The development of workplace monitoring and medical surveillance systems are done with the aid of consultant Toxicologists and Occupational Health Specialists. These systems have to comply with the Nuclear Licence and Hazardous Chemical Substances Regulations.
Development and maintenance of, and support to Nuclear Facility Managers with the implementation of the ALARA programme.
The technologists, scientists and engineers in this group are appointed as Radiation Protection Specialists (RPS), Criticality Specialists and/or Nuclear Material Transport Specialists.
Radiation Protection Specialists (RPS) are responsible for ensuring that the Necsa Radiation Protection Programme is developed implemented and reviewed and that all applicable licence conditions are met with a view to assuring the safety and health of workers and public without compromising the environment.
The RPS has the authority to stop any work or process, which contravenes the licence conditions or HSE requirements.
Nuclear Material Transport Specialists are responsible to assist in the development of a Necsa system to comply with the requirements of the National Road Traffic Act (No 93 of 1996), requirements of the IAEA's transport requirements TS-1-(R) (ST1 revised), INFCIRC 225 and various incorporated SABS standards.
The Specialists also act as INES single point contact for the reporting of nuclear events, rated at level two and above, to the INES national officer (in the employmentr of the NNR).
Safety Support Group
Safety Support is responsible for:
- The reporting of injuries on duty to the Department of Labour's Inspector of Machinery (in accordance with Act 85 of 1993) and investigation with line management of all injuries on duty and gathering of data for the Department of Labour's investigations.
- The development and maintenance of HSE procedures to assist line management in their operations.
- Rendering a back-up radiological protection service to nuclear facility managers in the event of facility Radiation Protection Officers (RPO) not being available or in the event of abnormal or additional activities resulting from nuclear occurrences or emergencies.
- Providing an RPO service to those facilities where the frequency of nuclear activities does not warrant permanent RP personnel.
- Performing special investigations into occurrences reported to the NNR.
- Providing back-up portable radiation and contamination monitors to adequately monitor radiological hazards as a support for facility RPOs during occurrences/emergencies.
- Certification of electrical installations in accordance with the Electrical Installation Regulations and inspection of all new and existing electrical installations to ascertain compliance with Act 85 of 1993 and with SABS 0142: Wiring Code.
- The evaluation of electrical designs and drawings and the inspection of electrical equipment in fire hazard areas in compliance with the Electrical Machinery Regulations.
- Developing and managing of the NECSA's HSE awareness programme (e.g. training, competitions, posters and bulletins, etc) and is responsible for the HSE training programme (i.e. scheduling, presenting, recording, certification, etc. of HSE training courses).
- Maintenance of a nuclear occurrence registers, follow-up and reporting on a corporate level on progress with the closeout of occurrences.
- Assistance to Nuclear Facility Managers with interim and closeout reports.
- Providing an audit function to verify compliance with the NECSA HSE-system (including the radiological protection system).
- Assisting line management in the corrective action process and follow-up of corrective actions implemented and the effectiveness thereof.
- Auditing of private tenant's HSE performance to determine compliance with the contract and those HSE requirements that could impact NECSA.
- Providing feedback to Property Management where the activities of a private tenant may have a negative impact on NECSA.
- Providing a central register for listed electronic products and for all radioactive sources used on-site and report status to NNR and Department of Health. Ensure that routine leak tests are performed.
- Keeping of all statutory required certificates of pressure vessels, boilers, lifts, etc.
Medical Station Services
The Medical Station Group is responsible for the following services:
- The maintenance of an adequately staffed medical centre and the provision of a medical service including routine medical examinations of occupationally exposed persons (radiation, chemical, laser and noise workers).
- Pre- and post-employment medical examinations, treatment of casualties and primary health care. Use is made of consulting Medical Practitioners to perform the medical examinations.
- The development and implementation of subsidiary medical surveillance programme procedures.
- Ensuring that there is the ability to deal with chemical, radiological and other casualties at NECSA. This service includes a medical dispensary.
- The maintenance and operation of calibrated X-ray, audiometry, lung function and blood sample analysis and vision testing apparatus.
- Facilities are also provided to deal with radiological or chemically contaminated patients.
- Implementation and maintenance of a registration and records system for occupational exposed persons.
- Dosimetry systems to measure levels of radiation exposure to workers.
- Maintenance of a whole body and lung counter facility to routinely monitor radiation workers in order to determine whether they have inadvertently been exposed to radionuclides.
- Radiation workers also use the apparatus to quantify known intakes of radionuclides. (This service is also rendered to other organisations.)
- Rendering of private health care services and running primary health care clinics.
Emergency Services Group
The Emergency Services Group consists of a highly trained radiological protection team on standby; to guarantee the provision of a 24-hour response capability to any emergency, on the NECSA site or nationally. Emergency services such as fire fighting and ambulance services are provided on the NECSA site as well as for the community in the vicinity of NECSA.
Emergency Services are also responsible for:
- Operating a 24-hour manned Emergency Control Centre (ECC). The ECC provides for the monitoring of fire alarms in production facilities, office buildings and workshops.
- Emergency communication with NECSA facilities and response teams (SAPS, SANDF, Civil Emergency and Disaster Management groups)
- An auto-dial system to the public and radio stations in compliance with the NECSA - emergency plan.
- Maintaining an infrastructure for the training of emergency functionaries.
- Voice logging of all incoming telephone and radio calls.
- Receiving, recording and referral of complaints and queries from the community.
- Assessment of new projects and existing production facilities and activities to identify fire hazard areas and activities. Fire protection and prevention measures are followed and detection, fire fighting and control and quenching equipment are provided.
- The final classification/declassification of fire hazard areas in accordance with SABS-0108: The Classification of Hazardous Locations and the Selection of Apparatus for use in Such Locations.
- Providing a comprehensive fire brigade service including approval of building plans submitted to the local government. NECSA Emergency Services has a contract with the Local Council to provide the service, which includes the investigation of fires and other emergency incidents to determine root cause and recommendation of preventive measures.
- NECSA’s Emergency Service is a designated service in terms of the Fire Brigade Services Act, Act 99 of 1987, and all operational personnel are registered with the South African Medical and Dental Council.
- The development and maintenance of the HSE statistics system for the measurement of NECSA’s HSE performance and to assist management to manage their HSE responsibilities. The HSE statistics system provides for the allocation of direct cost to all injuries and incidents.
- Providing a complete register of all incidents on the NECSA site. Incidents include disabling injuries, first aid injuries, incidents with and without loss, nuclear occurrences; motor vehicle accidents (on and off-site) and off-site incidents (i.e. community incidents) that the Emergency Services were involved in.
- Reporting, record keeping and liasing with the Compensation Commissioner in accordance with Act 130 of 1993) of all injuries on duty.
- Training of NECSA personnel in all emergency related functions such as fire fighting, first aid, the use of breathing apparatus, work permit system, etc.
- Administrating the Conventions for Early Notification and Technical Assistance. These IAEA conventions provide for cross country notification of and assistance during nuclear events. Emergency Services report these events to the IAEA's office in Vienna.
- Joint emergency planning with the SAPS, SANDF, Local Emergency and Disaster Management Groups, and representatives of the community.
- Representing NECSA on the PRETSOM forum between Fire Brigades.
Risk Analysis Group
The Risk Analysis (RA) Group is responsible to do risk assessments for nuclear, chemical and mechanical facilities. Technical, health, scientific and engineering fields are combined in risk analysis.
The nuclear licence and the Major Hazard Installation Regulations require Necsa to perform Probabilistic Risk Assessments (PRA) of nuclear and chemical facilities. The NNR will not consider a licence change request without a PRA. Probabilistic Risk Assessments of nuclear facilities have to be reviewed annually and those of chemical facilities once every three years. The site PRA for chemical facilities also has to be submitted to the Department of Labour and to Local Authorities.
Risk Analysis also liases with the NNR and the government organisations in regards to PRAs.
Advice is given to facility designers with regard to the reliability of systems, the inherent risk associated with certain design aspects, and assisting in decision-making. Advice is also given to existing facilities in improving health, safety and environmental aspects.
Events/Incidents occurring in nuclear and chemical facilities are assessed and compared with PRA findings. This may lead to the revision of PRAs.
Risk Analysis provides a specialist service during the design, fabrication and installation phases of projects and plant modifications. The group advises project team leaders in the requirements of internal Necsa and external approval of projects and plant modifications.
This group is responsible for configuration of licences and permits and keeping records of all safety assessments, PRAs as well as for other HSE records (e.g. injuries on duty) prescribed by various Acts and Regulations. Records are kept and distributed to nuclear facility and discipline managers of NL27/28, as well as nuclear licenses and all correspondence with and from the NNR.
Risk Analysis is also responsible for assessment of prospective private lessees' impact on Necsa's HSE responsibilities before being accommodated on the Necsa site. Private lessees with unacceptable impact are not accommodated.
The Environmental Management Group mainly evaluates new projects and existing plant/facilities (Necsa and private tenants) for compliance with the EMS. Recommendations, corrective measures and advice are given to project leaders and facility managers regarding environmental impact reports to the authorities.
Environmental Management also:
- Investigates environmental related occurrences, recommend corrective measures and reports about the actions taken and the effectiveness thereof.
- Represents Necsa on the Industrial Environmental Forum.
- Prepares Necsa's annual environmental report.
- Reviews the environmental impact of new facilities, the non-compliance with licence conditions from an environmental viewpoint and annual environmental and meteorological reports.
- Liases with the NNR and other government authorities with regard to the environmental matters.
The Environmental Monitoring Group supervises all environmental activities to ensure that it meets licence and permit requirements.
This Risk Assessment Group provides assurance on compliance to requirements and the adequacy of predictions made by risk analyses with regards to environmental impacts.
Environmental monitoring includes:
- Corporate routine environmental and meteorological monitoring as required by the NL27 and NL28 licences, independent of the plant operators.
- Corporate routine environmental monitoring to ensure compliance with the requirements of any permit, condition or authorisation of a government, provincial or local authority.
- Corporate routine environmental monitoring in terms of Necsa's Environmental Management System (EMS).
- Arranging analysis of samples, interpretation of data and entering data on a database.
- Investigation of any non-compliance revealed by monitoring results or of any incident impacting, or potentially impacting the environment.
- Reporting of environmental and meteorological results corporately and to relevant authorities as per the EMS permits and licences.
- Ensuring further independent verification of monitored results by arranging for sampling and appointing external consultants for sampling or analysis.
- Providing special or routine environmental monitoring services to internal and external clients.
- Providing emergency environmental and meteorological monitoring services for emergency planning and control purposes.
- Providing environmental management functions in support of the EMS and of the specialist corporate environmental function.
Protection Services Group
Protection Services are responsible for the development and maintenance of corporate policy, procedures and instructions for protection of Necsa assets.
Necsa policy, procedures and instructions include:
- Physical security measures.
- Information protection (in compliance with the Government's Minimum Information Security Standard)
- Security awareness and crime prevention campaigns.
- Negotiations and administration of the contract with private security forces for Necsa's physical security.
- Provision and maintenance of an effective access control system. This service includes the control of visitors through issuing of access cards and liaison with hosts.
- Ensuring Necsa's compliance with the IAEA's Conventions for the Physical Protection of Nuclear Material (INFCIRC 225) and "Preventing, Detecting and Responding to Illicit Trafficking in Radioactive Materials".
- Assessment of the protection measures of nuclear facilities on an annual basis and other facilities at least every second year.
- Recommendations to line management in regard to improvement of security measures, also in view of occurrences.
- Preparation and submission to the NNR of NECSA's overall general security measures as well as facility security procedures.
- Compliance with the National Key Points Act (Act 102 of 1980).
- Some of Necsa's facilities are registered as National Key Points. These facilities have to comply with Act 102 of 1980, including directives and regulations. This Act requires notification of the Protection Authority of security related occurrences and the establishment of an emergency organisation (including e.g. SAPS, SANDF) to control security related occurrences. These requirements are also covered in Necsa's emergency plan.
- Provision of physical security at identified facilities when needed and an escort service when transporting nuclear material or other hazardous/valuable items on request.
- Internal investigation of reported irregularities on the Necsa site (including private tenants). This process culminates in the handing over of the case dossier to the Necsa Human Resources Group for pre-disciplinary investigations including a decision to hand over the case to the SAPS. Serious offences are immediately handed over to the SAPS.
- Rendering of an internal security service with regard to escorting of "difficult" employees and customers/visitors off the Necsa premises. This service also includes support to Welfare Services of the Human Resources Group.
- Implementation of Necsa's security clearance system for Necsa personnel, contractors and tenants. This system provides for different levels of security clearance by the SAPS.
- This responsibility also includes the record keeping of security clearance documents and recommendation to line management on the seriousness of offences and liaison with SAPS and the National Intelligence Agency.
- Training of contract security guards to a National Key Point level including training in the various Necsa procedures and other requirements.
The following documents are referenced in this section:
- Act 85 of 1993 : Occupational Health and Safety Act
- Act 93 of 1996 : National Road Traffic Act
- Act 99 of 1987 : Fire Brigade Service Act
- Act 102 of 1980 : National Key Points Act
- Act 130 of 1993 : Compensation for Occupational Injuries and Diseases Act
- SABS 0142 : Wiring Code
- SABS 0108 : Classification of Hazardous Locations and the Selection of Apparatus for use in such Locations
- INFCIRC225 : Physical Protection of Nuclear Material
- ISO 14001 : Environmental Management Systems - Specification with guidance for use
The Occupational Health and Safety Act 85 of 1993 requires Necsa to appoint a competent person to ensure that all equipment and facilities comply with the requirements and standards incorporated in the Act.
This function includes the purchase, installation, operation, maintenance of and modification to machinery. The competent person should have a Government Certificate of Competency.
Risk Management's Senior Manager is appointed as Necsa's Competent Person and performs the following duties:
- The safety approval process of projects
- Comments and approves design and manufacturing of non standard statutory equipment
- Performs plant inspections to ascertain compliance with requirements
- Provides a support service to business management in regard to requirements of the Act for the safe operation of their facilities
- Investigate occurrences/injuries and prescribes corrective actions and the implementation thereof.
Subordinate Competent Persons are appointed for facilities, where appropriate, by the Competent Person to assist the Competent Person in the execution of these functions.
This responsibility, only covers Necsa machinery, but private lessees benefit from this function through the audits of the Safety Support Group.
ALARA As low as Reasonably Achievable
EMS Environmental Management System
HSE Health, Safety and Environment
ICRP International Commission on Radiological Protection
IAEA International Atomic Energy Agency
INES International Nuclear Event Scale
Necsa South African Nuclear Energy Corporation
NNR Council for Nuclear Safety
PNI Pelindaba Nuclear Institute
PRA Probabilistic Risk Assessment
RM Risk Management
RP Radiation Protection