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Home , Energy development, Ionizing radiation

Overview and Analysis of Legal Documents and Technical Regulations on Safe Management of Radioisotope Thermoelectric Generators

S.G.Testov, Department of State Supervision over Nuclear and Safety, Ministry of Defense of the Russian Federation

1. Background

Presently there are about 900 radioisotope thermoelectric generators (RTG) in operation in the Russian Federation. RTGs are used by the Ministry of Defense of the Russian Federation, by the Federal Agency for Maritime and River Transportation (Rosmorrechflot), by the Federal Agency for Hydrometeorology and Environment Monitoring (Roshydromet) as autonomous sources of electric supply of different technical devices located far off settlements and stationary power transmission lines. The majority of RTGs (about 90 %) are operated by the Russian Navy and Rosmorrechflot to supply power to navigation equipment (lighthouses and different beacons). RTG is a rather reliable (Figs. 1 – 3) which retains its operability for 15 – 20 years with minimum maintenance. Till recently the use of RTGs was considered to be the optimal solution in providing reliable operation of navigation means. However, the cases of unauthorized access to RTGs, their damaging, withdrawal of thermal radioisotope sources (TRS) have obviously demonstrated that, being highly reliable devices, RTGs are a huge potential hazard both for the people and the environment. TRSs are characterized by very high radioactivity – initial Sr-90 activity in a RTG is about from 1,3*10+12 to 2*10+13 Bq (35 to 540 kCi) depending on RTG type with relatively small dimensions and weight. In case of dispersion of the above radioactivity on the surface, the area of the territory subject to alienation will constitute from several to tens of square kilometers. It is significant that the area of the contaminated territory is rather determined by the method of dispersion than by TRS radioactivity. The practical experience of the group of specialists in radiation, chemical and biological protection of the Northern Fleet of RF Navy working jointly with the experts of the Main Administration for Navigation and Oceanography of the Ministry of Defense of the Russian Federation, who have repeatedly mitigated the consequences of unauthorized disassembling and vandalism in relation to several RTGs in Murmansk region, brought rather alerting indirect result. With sufficient special training of the supervisor of the works a small well organized and disciplined group can dismantle RTG and withdraw the TRS rather quickly without any serious hazard to their health. The readiness of the members of the group to definite self-sacrifice increases its chances for success immeasurably. Fortunately, the goal of the above facts of disassembling and vandalism was to steal non-ferrous metals and not the use of radioactivity for the purposes of terrorism. The awareness of these factors has resulted in making a decision on planned replacement of RTGs with alternative safe power sources (Fig. 4). This has started several years ago. However, the dramatic changes in the situation in the country as well as worldwide necessitates the acceleration of the process of the replacement of RTGs with alternative power sources as well as taking technical and organizational measures to reduce the probability of theft of TRSs from RTGs in operation.

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Figure 1

Figure 2

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Figure 3

Figure 4

3 Testov-eng The Ministry of Defense of the Russian Federation has performed definite work to establish conditions for safe management of RTGs, and the agenda of the workshop envisages further presentations devoted to this work, while my task is to make the review and analysis of existing legal documents and technical regulations on providing safety in RTG management.

II. The structure, the list and brief overview of legal documents and technical regulations on providing radiation safety and physical protection of radioactive substances and radiation sources

The structure of legal documents and technical regulations on safe management of radioactive substances and radiation sources is presented below:

1. Constitution of the Russian Federation

2. Federal Laws of the Russian Federation

3. Decrees and Orders of the President of the Russian Federation

4. Decrees and Orders of the Government of the Russian Federation

5. Federal Regulations and Rules

6. State Standards, Directions and Methodological Guidelines of Safety Regulatory Authorities

7. Interdepartmental and Departmental Normative Documents

The principal documents and relevant comments are given below.

1. Constitution of the Russian Federation

Article 71 proclaims: «The following is under the jurisdiction of the Russian Federation: i) federal power grids, generation, fissile materials, federal transport, routes, information and communication, activities in space». Article 72. «The following is under the joint jurisdiction of the Russian Federation and

4 Testov-eng the Subjects of the Russian Federation: e) nature management; protection of the environment and ensuring ecological safety; specially protected natural territories; protection of the monuments of history and culture; j) coordination of the issues of public health; protection of family, motherhood, fatherhood and childhood; social care including social security; h) implementation of measures of struggling with catastrophes, natural , epidemics, elimination of the consequences thereof.».

2. Laws of the Russian Federation

1. Federal Law «On Public Radiation Safety» The Law determines the legal basis of ensuring radiation safety of the public with the aim to protect its health. The law establishes the system of the bodies of executive authorities, state regulation and licensing of activities in the area of ensuring radiation safety (RTG management inclusive). The law also sets forth the general requirements to ensure radiation safety in the basic industrial activities (including the use of such powerful radiation sources as RTGs) and to ensure radiation safety in case of radiological accidents involving radiation sources. «Public radiation safety – is the state of protection of the present and future generations of people against effects harmful to their health (Article 1). «The citizens of the Russian Federation, the citizens of foreign states and persons without citizenship residing on the territory of the Russian Federation have the right for radiation safety. This right is ensured by implementing the set of measures to prevent the impact of ionizing radiation upon beyond the established norms, rules and standards» (Article 22).

2. Federal Law «On the Uses of Atomic » The Law determines the legal basis and principles for regulating the relations arising from the use of atomic energy and is aimed at the protection of human health and life, protection of the environment, protection of property while using atomic energy and urges to promote the development of nuclear science and , to facilitate strengthening of the international regime of safe use of atomic energy. The principal objectives of legal regulation of the relations are: to establish legal basis of state management and state regulation of safety in the use of atomic energy; to fix the rights, duties and responsibilities of citizens, officials, enterprises and organizations as well as those of federal executive authorities in the sphere of relations pertaining to the use of atomic energy. The objects of application of the Law are nuclear facilities, radiation sources (RTGs inclusive), storage facilities for and radioactive substances (RTGs storage facilities), storage facilities, nuclear material, radioactive substances, radioactive waste.

3. Federal Law «On Public Sanitary and Epidemiological Well-Being» The Law sets forth sanitary and epidemiological rules and standards, determining the safety criteria, non-compliance to which creates hazard to human life or health as well as the hazard of appearing and dissemination of diseases. «Production, use, storage, transportation and disposal of radioactive substances, other sources of ionizing radiation (RTG) is allowed only on the permission for these kinds of

5 Testov-eng activities by the authorities or institutions of the State Sanitary and Epidemiological Service of Russia» (Article 21). «Production and consumption waste (decommissioned RTG) are subject to collection, use, rendering safe, transportation, storage and disposal, the conditions and methods of which should be safe for public health and the biotope and which should be performed in compliance with sanitary and other normative legal documents of RF » (Article 22). «Following sanitary rules is compulsory for individuals, individual entrepreneurs and legal entities» (Article 39). «Violation of the sanitary legislation is subject to disciplinary liability or administrative or criminal responsibility» (Article 55).

4. Federal Law «On the Protection of the Natural Environment» The Law determines the legal basis for the state policy in the area of environment protection to ensure balanced solution of social and economic problems, preservation of favourable environment, biological diversity and natural resources to satisfy the demands of the present and future generations, strengthening law and order in the area of environment protection and ensuring ecological safety. «The governmental authorities in the Russian Federation in the sphere of relations concerned with environment protection are: …establishing the procedure of radioactive and management, control of radiation safety ensuring…» (including the control of ensuring radiation safety in RTG management) (Article 5). «1. Production and consumption waste, including radioactive waste (decommissioned RTG) are subject to collection, use, rendering safe, transportation, storage and disposal, the conditions and methods of which should be safe for the environment and regulated by RF legislation»

5. Federal Law «On the Protection of the Population and Territories against Natural and Man-Caused Emergencies» The Law determines Russia-wide legal norms in the area of protection of the citizens of the Russian Federation, foreign citizens and persons without citizenship residing on the territory of the Russian Federation, of all land, water and air space within the limits of the Russian Federation or a part thereof, the objects of industrial and social nature as well as the natural environment against natural and man-caused emergencies (loss of integrity of the radiation shielding of a RTG in case of an unauthorized action may cause contamination of the environment by radioactive substances, which is a man-caused emergency situation).

6. Federal Law «On Environmental Expertise» The Law regulates the relations in the area of environmental expertise (review) and is aimed at the implementation of the constitutional right of the citizens of the Russian Federation to favourable environment by means of preventing the negative impacts of business and other activities on the natural environment and in this part envisages actualisation of the right of the Subjects of the Russian Federation for joint – with the Russian Federation – treating of issues of environment protection and ensuring environmental safety. Environmental safety is determining the compliance of the planned business or other activity to the environmental requirements and determining the permissibility of the object under environmental expertise with the aim to prevent possible unfavourable impacts of this activity on the natural environment and related social, economic and other consequences of implementing the object under ecological expertise. (All projects to create conditions for RTG safe management, including the projects for construction of RTG storage facilities, should be subjected to environmental expertise).

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7. Federal Law «On Administrative Responsibility of Organizations for the Violation of the Legislation in the Area of the Uses of Atomic Energy» The Law determines the administrative responsibility of organizations for the violation of the legislation in the area of the uses of atomic energy and calls for enhancing the efficiency of state regulation of safety while using atomic energy and is aimed at strengthening the protection of human health and life and the environment. (Violation of the legislative requirements in RTG management causes administrative and/or criminal responsibility).

3. Decrees and Orders of the President of the Russian Federation

1. The Fundamentals of the State policy in the Area of Ensuring Nuclear and Radiation Safety of the Russian Federation for the Period till 2010 and for Further Prospective. Approved by the President of the Russian Federation on December 4, 2003 (№ Pr-2196). This document determines the objectives, priority directions, the basic principles and tasks of the state policy in the area of ensuring nuclear and radiation safety in the Russian Federation, as well as the directions of programmatic-targeted planning and management in this area. The legal basis of the Fundamentals is the Constitution of the Russian Federation, federal laws and other legal documents as well as international treaties, agreements and conventions in the area of ensuring nuclear and radiation safety which the Russian Federation participates in. The Fundamentals proclaim that ensuring nuclear and radiation safety is one of the most important components of ensuring national security of the Russian Federation. (Thus, the standards' requirements to RTG management should also comply with international requirements). 2. The Decree of the President of the Russian Federation of August 16, 2004 No. 1082 «The Matters of the Ministry of Defense of the Russian Federation». This document approves the status of the Ministry of Defense of the Russian Federation and entrusts it to perform state supervision for nuclear and radiation safety in the development, , testing, operation, storage and decommissioning of nuclear weapons and nuclear power installations for military purposes. (As far as RTG is not a nuclear facility, supervision and regulation of RTG safe management is performed by the Federal Environmental, Industrial and Nuclear Supervision Service of Russia).

4. Decrees of the Government of the Russian Federation

1. The Decree of the Government of the Russian Federation «On the federal targeted program «Nuclear and radiation safety of Russia» for 2000 – 2006 (of February 22, 2000, No. 149). The Decree approves the targeted program «Nuclear and radiation safety of Russia» for 2000 – 2006 and determines federal authorities responsible for the implementation of the program. (RTGs management as the management of high capacity radiation sources is within the sphere of this targeted program).

2. The Decree of the Government of the Russian Federation «On the Approval of the Rules for Organization of the System for State Accounting and Control of Radioactive Substances and Radioactive Waste » (of October 11, 1997, No. 1298). It regulates the routine of the state accounting and control of radioactive substances and radioactive waste in the system of state accounting and control of radioactive substances and radioactive waste in the Russian Federation and is compulsory for implementation by all legal entities irrelevant of the

7 Testov-eng form of property and organizational and legal form. State accounting and control of radioactive substances and radioactive waste is aimed at determining its actual amount, at preventing losses, unauthorized use and theft. (In accordance with the Rules RTGs are subject to accounting and control).

3. The Decree of the Government of the Russian Federation «On the State Competent Authority on Nuclear and Radiation Safety in Transportation of Nuclear Material, Radioactive Substances and Items Made Thereof» (of March 19, 2001, No. 204). It approves the Status of State competent authority on nuclear and radiation safety in transportation of nuclear material, radioactive substances and items made thereof (Minatom of Russia – presently – “Rosatom”) and makes Minatom of Russia responsible for organizing cooperation of the relevant executive authorities, executive bodies of the Subjects of the Russian Federation, local governments bodies, Russian Academy of Sciences and organizations. (In compliance with the above Decree, RTGs transportation should be performed upon getting certificates-permissions, issued by Rosatom as the competent authority).

4. «On Federal Environmental, Industrial and Nuclear Supervision Service». It approves the Status of the federal service on environmental, industrial and nuclear supervision and states that the Federal service on environmental, industrial and nuclear supervision (Rostekhnadzor) is the regulating authority as per Convention on Nuclear Safety and Security and the competent authority of the Russian Federation as per Basel Convention on the control of transboundary transportation of hazardous waste and its removal. It entrusts Rostekhnadzor with the functions to issue normative legal documents, to control and to supervise in the sphere of environment protection in the part pertaining to the restriction of negative man- caused impact and safety in using atomic energy (excluding the activities in the development, manufacturing, testing, operation and disposal of nuclear weapons and nuclear power facilities for military purposes) as well as the functions of state safety regulator in the uses of atomic energy (as it was pointed out before, RTGs are in the sphere of regulation and supervision of Rostekhnadzor).

5. The Decree of the Government of the Russian Federation of June 28, 2004 «On the approval of the Status of the Federal Agency for Atomic Energy» It approves the Status of the Federal agency for atomic energy (Rosatom) and states that Federal agency for atomic energy is the plenipotentiary federal executive authority performing the functions for promoting state policy, normative and legal regulation, rendering state services and managing state property in the sphere of uses of atomic energy, development and safe operation of nuclear power engineering, nuclear weapons complex, nuclear cycle, nuclear science and technology, nuclear and radiation safety, non-proliferation of nuclear material and , as well as international cooperation in this sphere. (Rosatom is the legal successor of Minatom of Russia and performs state management in the sphere of uses of atomic energy, including the management of nuclear material and radiation sources (including RTGs).

5. Federal standards and regulations 1. Radiation safety standards (NRB-99, SP 2.6.1.758 - 99). Approved by the Chief state sanitary inspector of the Russian Federation on July 2, 1999. The norms are based on international basic safety norms for radiation sources jointly enacted by: UN and Agricultural Organization, International Atomic Energy Agency, International Labour

8 Testov-eng Organization, Nuclear Energy Agency, Organization for Economic Cooperation and Development, Pan-American Health Organization and World Health Organization. The Standards are used to ensure human safety in all conditions of the impact of ionising radiation of artificial or natural origin. “The Standards” is the principle document which regulates the requirements of the Federal Law «On Public Radiation Safety» through stating basic dose limits, permissible ionising radiation impact levels and other requirements on restricting human . (NRB-99 determines the basic dose limits in RTG management).

2. Basic sanitary rules to ensure radiation safety (OSPORB-99, SP 2.6.1.799-99) Approved by the Chief state sanitary inspector of the Russian Federation on December 27, 1999. The Rules establish the requirements to the protection of people against harmful radiation effects in all conditions of irradiation from ionizing radiation sources which are subject to NRB-99. The Rules are compulsory for the application on the territory of the Russian Federation for all legal entities irrelevant of their subordination and forms of property, the result of the activity of which may result in irradiation of people as well as for the administrations of the Subjects of the Russian Federation, for local administrations, citizens of the Russian Federation, foreign citizens and stateless persons, residing on the territory of the Russian Federation. The Rules are compulsory in design, construction, operation, reconstruction, changing the area of activities, decommissioning, rehabilitation of radiation facilities and disposal of radiation sources (Establishe the requirements to personnel and public protection in RTG management).

3. Sanitary rules for the management of radioactive waste (SPORO-2002. SP 2.6.6.1168-02). Approved by the Chief state sanitary inspector of the Russian Federation on December 27, 1999. The Rules establish the requirements to ensure public and personnel radiation safety in all kinds of radwaste management. The rules comprise radwaste classification, basic principles of radwaste management, radiation safety criteria in radwaste management, basic requirements to ensure safety of the personnel and public at all stages of radwaste management: in collection, storage, transportation, processing and disposal in nuclear power engineering enterprises and other organizations where radwaste is generated. (Establish the requirements to the management of RTGs, which are decommissioned and reclassified as radwaste).

4. Sanitary rules for radiation safety of the personnel and public in transportation of radioactive material (substances) (SanPiN 2.6.1.1281-03). Approved by the Chief state sanitary inspector of the Russian Federation on April 16, 2003. The Rules establish the hygienic requirements to ensure public and personnel radiation safety in all kinds of radioactive material management in transportation from the moment of shipping by the consignor till receiving by the consignee. (Establish sanitary safety requirements in RTG transportation).

5. Safety rules in transportation of radioactive substances (NP-53-04). Approved by resolution of Rostekhnadzor on October 4, 2004, No. 5. The rules establish technical measures to ensure safety in transportation of radioactive substances by , air, rail, sea and river transport and are compulsory for all enterprises, organizations and institutions of all ministries and departments which perform shipping, transportation, handling and storage of radioactive substances. The rules establish the requirements for safe transportation of radioactive substances outside the territory of the enterprise which produces radioactive

9 Testov-eng substances. (The rules establish organizational and technical measures for safe transportation of RTGs).

6. Rules for physical protection of radiation sources, storage facilities, radioactive substances (NP-034-01). Approved by the resolution of Gosatomnadzor of Russia on January 16, 2002, No. 3. The rules cover physical protection of radiation sources, storage facilities, radioactive substances at all stages of design, construction, operation, decommissioning as well as in management of radioactive substances. (The rules establish organizational and engineering technical measures for physical protection of RTGs in transportation, storage and operation).

6. State Standards, Directions and Methodological Guidelines of Safety Regulatory Authorities

1. State standard (GOST) «Thermoelectric radioisotope generators. Acceptance rules and test methods. GOST 20250-83». Establishes acceptance rules and test methods for all types of RTGs.

2. State standard «Thermoelectric generators. Types and general requirements. GOST 18696-90». Establishes the types and general technical requirements to for manufacturing by producers.

3. State standard «Safety in emergency situations. Radioactive substances individual protection means. General technical requirements. GOST R 22.3.06-97». Establishes the requirements to individual protection means in the course of elimination of the consequences of radiation accidents, the routine for the use of individual protection means in different concentrations of radioactive substances in the air and on the surfaces of the equipment (RTG accidents inclusive).

4. State standard «Transportation packages for radioactive substances. General technical requirements. GOST 16327-88». The standard covers transportation packages designed for the transportation of radioactive substances (RTGs inclusive) by all modes of transportation outside the territory of the enterprises where the substances are produced and used and establishes requirements to the above. Transportation packages should be stable in transportation and provide protection against ionizing radiation.

5. State standard «Special form radioactive material. General technical requirements and test methods. GOST R 50629-93. (In our case establishes general technical requirements to and test methods of encapsulated radionuclide thermal sources RIT-90 as to special form radioactive material).

6. Methodological guidelines «Radiation situation monitoring. General requirements» (MG 2.6.1.14-2001) set forth general requirements to organization and performing monitoring of radiation situation at the enterprises, performing the activities using ionizing radiation sources, including the purpose, goals and tasks of monitoring, requirements to instrumental, methodological support and measurement assurance, to the scope and to the regulations of the monitoring, to accounting for monitoring results. (For the enterprises which develop, manufacture, disassemble and dispose of RTGs).

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7. Interdepartmental and Departmental Normative Documents

1. Provisional regulations on the procedure of issuing certificates-permissions for special form radioactive material, for the design and transportation of packages with radioactive substances (PVSR-92). Interdepartmental document approved by the heads of Minatom, Gosatomnadzor and Federal Administration “Medbioextreme”. This document establishes the procedure of issuing certificates-permissions for transportation and design of packages for special form radioactive material (TRS), for special conditions of the transportation, for special form radioactive material and for the items, the use of which is associated with transportation (for RTG design).

2. Rules for operation and decommissioning of radionuclide power installations on the basis of radionuclide thermal sources using Sr-90. Interdepartmental rules of the RF Navy and Rosatom, approved by the first deputy minister of the Russian Federation for atomic energy on December 22, 1999. The rules establish the responsibilities of all organizations participating in RTG decommissioning and disposal. Issuing certificate-permission confirms the compliance with all necessary requirements of safe transportation rules in effect and gives the right to perform the transportation indicated in the certificate without additional coordination (if not stated otherwise in the certificate-permission) with state supervision and safety authorities.

3. «Transport container. Testing program and methodology.» YaNMI.305179012 PM. The document presents the guidance for performing acceptance and periodic testing of a transport container after manufacturing thereof. The procedure for testing is as per GOST 15.309-98. The document comprises: general provisions, general requirements to the conditions of testing, testing methods, safety requirements. (Transportation of RTG from the enterprise, which performs TRS dismantling, to disposal, should be performed in containers, tested in compliance with the above program).

4. Rules of hydrographic service No. 23.(PGS-23) «Radioisotope power devices». Approved by the Chief of the Main Department of Navigation and Oceanography of the Ministry of Defense of Russia. The Rules describe the design of a RTG, define concretely the rules for safe transportation, storage, maintenance of RTGs, define safety measures during the work with RTGs.

5. Instructions and guidelines to assure radiation safety in the Armed Forces and in the Navy, in different forces of the Armed Forces, manuals on assuring radiation safety. (Establish general requirements on radiation safety in radioactive substances and radioactive sources management, RTGs inclusive).

6. Technical specifications for radioisotope power installations in general and for the components thereof, technical descriptions, RTG operational manuals.

III. Requirements set forth for the organizations and enterprises which develop and manufacture RTGs

An enterprise which develops and manufactures RTGs is responsible for the manufacturing of RTGs and their components in compliance with the Rules for acceptance

11 Testov-eng and testing, with the requirements of the regulations for assuring radiation safety, state standards and technical specifications. The enterprise should possess the sanitary and epidemiological certificate for the right to work with radioactive substances and possess licenses for the following kinds of activities: - to develop and to design radiation sources (to develop and to design items, which comprise radioactive substances); - to manage radioactive substances in manufacturing, use and storage; - to manufacture items which comprise radioactive substances; - to operate and to decommission radiation sources. The enterprise should assure: - radiation and environmental safety of the supplied RTGs on the level of the requirements of standards and regulations in effect; - availability of certificates-permissions for the design of the packaging and its transportation; - warranty and post-warranty maintenance of RTGs in operation, in performing scheduled maintenance works and other works envisaged by standards and regulations for a specific item; - participation in the inspection of the RTGs with the aim to make a decision on the extension on furthering their operation and extension of the service life; - provide interim responsible storing of the ready items till receiving the notification from the customer confirming its readiness to receive the items and to commission them; - training of the personnel of the operating organization to maintain RTGs; - participation in the works for decommissioning of RTGs with expired service life till handing over TRSs for disposal; - repair, restoration, upgrading of the item for its further use.

IV. Analysis of the requirements to ensure safety in RTG storage and operation

Operating organization is responsible for radiation safety and should provide: - compliance with the requirements of standards and regulations in the area of assuring RTG radiation safety and physical protection; - getting the licenses for performing the works with radiation sources; - development of the reference levels of radiation factors impacts and development of the manuals to assure radiation safety and physical protection in RTGs operation and storage; - systematic monitoring of radiation situation in the locations of RTGs operation and storage; - monitoring and accounting for personnel individual doses of radiation; - training and certification of the works supervisors and performers in assuring radiation safety; - timely information of the executive authorities, entrusted to perform state management, state supervision and control in the area of radiation safety, on the cases of emergency situations or accidents; - implementation of the resolutions and directions of the officials of the executive authorities performing state management and state supervision in the area of radiation safety. RTGs should be stored in specially equipped storage facilities, design, construction and acceptance of which should be performed in compliance with sanitary and building standards. Storage facilities should be equipped with alarm system and physical protection

12 Testov-eng system in compliance with the Rules for physical protection of radiation sources, storage facilities and radioactive substances. However, due to special and extreme conditions of RTGs operation (far from settlements, remote locations, high North latitudes, etc.) as well as due to the impossibility to satisfy all safety requirements, the rules for safe storage and operation of RTGs have some deviations from federal standards and rules. For example, though federal Rules for the physical protection of radiation sources, storage facilities and radioactive substances require for organizational and engineering and technical means of physical protection, alarm system, observation means, building structures, guards units and a great deal of other measures, the Rules for RTGs operation and decommissioning and the Rules of the Hydrographic Service for the works with RTGs envisage only the following measures of radiation safety and physical protection: - in storage the location of a RTG should be separated from the rest of the room or from the rest of the territory by physical barrier with warning inscriptions; - the rules for radiation safety pertaining to the transport packages of III transport category should be satisfied; - the level of gamma-radiation right against the surface of RTG shielding container should not exceed 2 mSv/hr, at 1 m distance – 0.1 mSv/hr, along the fencing of operating RTG – 1 µSv/hr; - the location of RTG operation should be fenced by any kind of fencing of at least 1.5 m high, the features of the relief, soil and other improvised means should be used as additional protection; - the fencing and RTG locations as well as the walls (doors) of the buildings where the RTGs are installed should be marked with trefoil symbol of radiation hazard as well as with warning placards (“Life hazard”, “Radioactivity”, “Watch out!”) which should be repeated in the national languages of the local population and clearly visible from at least 10 m distance (Fig. 5); - the operating organization within 10-days period should submit to the local supervisory authority and internal affairs authority the report on RTG commissioning; - the fact of availability of a RTG in the operational location and the integrity of its radiation shielding should be confirmed by the operating organization not later than 10 days after the violation of the normal operation of the installation. For remote locations confirmation should be made as soon as possible. In case the loss of integrity of a RTG is detected or the device has disappeared the local authorities of the Ministry of internal affairs should be immediately informed as well as the state supervision authority and the enterprise which has developed and manufactured the RTG; measures for the search and elimination of the consequences of the emergency situation should be taken. - basing upon the results of the inspection of RTG radiation, thermal and electric parameters, the commission appointed by Rosatom order, may extend the operational life of a RTG (but not longer than for 5 years). The results of the inspections of RTGs, operated by RF Navy, demonstrate, that in case radiation shielding components of transportation packages of RTGs are not destroyed, their radiation characteristics correspond to the above mentioned parameters, and the RTG packaging assures radiation personnel radiation safety and prevents contamination of the environment with radioactive substances. However, satisfying the above requirements pertaining to the unauthorized access to RTG both in operation and in interim storage before shipping for disposal, may prevent the access of only well-disciplined part of the public.

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Figure 5

There is an opinion, that there is no need to enhance the physical protection of RTGs in operation, as this will not assure reliable protection but may tempt to cancel further works for RTGs decommissioning and disposal. We believe that such attitude results from underestimation of the hazard which may be cause by a single TRS removed from RTG and misunderstanding of the function of RTG physical protection system. If the objective of the development of a RTG protection system is to develop and implement the measures aimed at preventing the possibility of delivering TRS to a location where it will be used for malevolent purposes, to compare the expenditures for the establishing the protection system with the possible losses due to radioactive contamination, which is so alluring to the deliberate criminals, and to refract all these factors through the of probabilistic calculations of the above assumptions, then one can suppose that RTG protection has higher priority than implementation of alternative power sources. No doubt, this is a provisional but urgent measure on the way to the final goal of complete RTG decommissioning.

V. Analysis of safety requirements in transportation of RTGs and TRSs

The basic legislative documents which regulate transportation of radiation sources are: Safety rules in transportation of radioactive substances (PBTRV-2005), Sanitary rules for radiation safety of the personnel and public in transportation of radioactive material (substances) (SanPiN 2.6.1.1281-03), State standard «Transportation packages for radioactive substances. General technical requirements». GOST 16327-88, and Provisional regulations on the procedure of issuing certificates-permissions for special form radioactive material, for the design and transportation of packages with radioactive substances (PVSR-92). The above documents are developed with the account for the “Regulations for the Safe Transport of Radioactive Material” (Vienna, IAEA, IAEA Safety Standards Series, No. ST-1, 1996 edition) and correspond to international standards.

14 Testov-eng Personnel and public radiation safety in transportation of radioactive material consignments shall be assured by: - using special conveyances and special packages, which assure protection of people against ionizing radiation, mechanical integrity of packages and prevent radioactive content leaks; - limiting the activity of radioactive material transported in one package; - preventing radioactive contamination of the surfaces of the packages and conveyances; - limiting the number of packages transported in one conveyance; - providing the required labelling of the consignment and the conveyance; - meeting the requirements of radiation safety by the personnel. Depending on the established limits of rate on the surface of the packages, the packages are classified into four transport categories. RTGs shall comply with the requirements to III transport category of packages. Packages of the III and IV transport categories are permitted to be transported only by specially equipped conveyances or in defined premises of vessels. From the view point of ability to provide security of radioactive material as well as to protect the environment from the hazardous impact, the packages are divided into Type A and Type B. RTG package corresponds to Type B – i.e. it meets the requirements set forth to it within the limits of permissible norms after a set of test for the compliance to normal and accident conditions of transport. RTGs may be transported by road, rail, air and sea. The conveyances for such purposes should have sanitary and epidemiological certificates, issued by the authorities of state sanitary and epidemiological supervision, to confirm the compliance of the conditions and means of transport of RTGs with sanitary regulations In transportation, RTGs should be put in a positions corresponding to the warning signs of the tare labelling and securely fixed to prevent spontaneous repositioning and turnover in turns, shocks, braking and rocking. RTG transportation shall be performed by an organization, which has the relevant licenses of the supervising authorities and certificates-permissions of the competent authority for nuclear and radiation safety in transportation of nuclear material, radioactive substances and items thereof (by Rosatom) as well as for the special form radioactive material, for the design of the item and for the transportation. It should be noted, that presently RTGs transportation by rail completely complies with the above requirements. RTGs transportation by rail is performed by special railcars designed for transport of radiation sources and radioactive substances, which belong to Federal State Unitary Enterprise “Atomspetstrans” of Rosatom. (Fig. 7). The analysis of the experience of decommissioning of RTGs and shipping them for further disposal demonstrates that to assure safe decommissioning and transportation, the Navy needs special vessels, equipped for the transport of radiation sources and specialized road (to deliver RTGs to interim storage facilities, to the locations of lading them to hydrographic vessels, etc.). The way out of the situation may be found on the ways of financing the repair and upgrading works of hydrographic vessels (which are required for every region – in the North, on the Baltic Sea, in the Far East) as well as financing for purchasing and equipping special road vehicles.

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Figure 6

VI. Requirements to safe RTGs decommissioning

RTGs with expired designed or extended life are subject to compulsory decommissioning for further disposal. In addition, a RTG is subject to decommissioning in case its parameters do not comply with the standards and are hazardous to the personnel, public and the environment. In case a decision is made not to use any longer a RTG-powered navigation beacon or to replace a RTG with an alternative power source, such RTG is also subject to early decommissioning. In any of the above cases prior to decommissioning the RTG should be inspected by the specialists of the designer and the manufacturer with the aim to assure the possibility of its dismantling and further safe transportation in compliance with the requirements of regulations and standards. Dismantling of a RTG from its location shall be performed by trained personnel of the operating organization under the supervision of the supervising authority. As per the Basic sanitary rules to ensure radiation safety (OSPORB-99), in order to perform the works, the warrant pass should be issued. The report on RTG dismantling should be sent to the designer and manufacturer as well as to the local supervisory and police authorities. in RTG decommissioning should comprise radiation monitoring of deceleration gamma-radiation dose rate and the monitoring of the contamination of the outer RTG surface in accordance with special routine. In case the dose rates and contamination levels exceed the prescribed values, relevant measures should be taken. Decommissioning of accident RTG requires for the development of special regulations for decommissioning, transportation, disassembly and disposal. Such regulations are presently developed for the accident RTG of the navigation beacon “Navarin” in Chukotka Peninsula. Finances are raised to implement the regulations.

16 Testov-eng Special regulation for the elimination of a RTG accident should comprise a section on the monitoring of the radiation situation in decommissioning of accident RTG, which should envisage radiation monitoring of deceleration gamma-radiation dose rate starting from far approaches to the device (on the assumption of loss of integrity of the radiation shielding or unauthorized disassembling of the device), as well as contamination and radiation monitoring in the process of accident mitigation using specially developed programs.

VII. Conclusions and proposals

The above overview of legal documents and technical regulations on ensuring safety in RTGs management demonstrates that the requirements of Russian legal documents and technical regulations basically comply with the requirements of international guidelines and – in case the requirements are met – assure radiation safety and public and personnel protection in full measure, as well as physical protection of radiation sources and protection of the environment against contamination with radioactive substances above the permissible limits. Actual status of RTG operation, storage, decommissioning and transport in the Navy demands for taking decisive measures. The worst bottlenecks are: - lack of sea vessels and road vehicles equipped in accordance with the modern regulations requirements to transport RTGs; - lack of storage facilities (sites) for interim storage of decommissioned RTGs waiting for disposal, equipped in compliance with modern requirements to physical protection; - lack of a monitoring system and lack of protection against unauthorized access by intruders to the locations where RTGs are operated. It follows from the above that presently the problem of protection against hazards, originating from RTGs, is of a multifaceted nature. The complexity of the problem originates from the fact that, on the one hand, it is impossible to replace in 2 – 3 years all existing RTGs with alternative power sources, and on the other hand – the lack of the system for protection and control of all RTGs in operation and in storage, corresponding to the requirements of the present day. It is widely understood, that it is also impossible to establish “classic” physical protection system for RTGs, which are scattered throughout the length of Russian coast line, and there is no safe alternative to RTGs. Besides, in accordance with international agreements Russia has to maintain properly the navigation means, thus the replacement of RTGs with alternative power sources should not result in reducing navigational safety. In compliance with the above we face the task to envisage the following principle measures to reduce the threat and eliminate RTG hazards: - the necessity of determining the priorities of the regions in replacement of RTGs with alternative power sources; - establishment of sites for interim storage of decommissioned RTGs, and equipping the sites with modern monitoring systems and systems to protect against unauthorized access; - making the choice of the alternative power sources depending on regional conditions; - dismantling of RTGs, the replacement of RTGs with alternative power sources; - development of handling and routing schemes in the process of RTGs decommissioning and shipping them to disposal; - increasing disposal capacity of the enterprise performing TRS disposal; - establishment of a protection system to prevent unauthorized access for RTGs which will stay in operation for some time.

17 Testov-eng