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UNITED ARAB EMIRATES
SECOND NATIONAL REPORT ON COMPLIANCE
WITH THE OBLIGATIONS OF THE JOINT
CONVENTION ON THE SAFETY OF SPENT FUEL
3 September 2014
MANAGEMENT AND ON THE SAFETY OF
RADIOACTIVE WASTE MANAGEMENT
OCTOBER 2014
UNITED ARAB EMIRATES
SECOND NATIONAL REPORT ON COMPLIANCE WITH THE
OBLIGATIONS OF THE JOINT CONVENTION ON THE SAFETY
OF SPENT FUEL MANAGEMENT AND ON THE SAFETY OF
RADIOACTIVE WASTE MANAGEMENT
OCTOBER 2014
United Arab Emirates Second National Report
Under the Joint Convention
Contents
United Arab Emirates Second National Report
Under the Joint Convention
United Arab Emirates Second National Report
Under the Joint Convention
United Arab Emirates Second National Report
Under the Joint Convention
Section A. Introduction
A.1
This is the second National Report of the United Arab Emirates (UAE) that has been
prepared in accordance with the Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management for review at the Fifth Review Meeting of the Convention to be held in May 2015. This National report describes the legislative, regulatory, and administrative measures and other steps taken by the United Arab Emirates to fulfil its obligations as a Contracting Party to the Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management. The
INFCIRC/604/Rev.3_Draft_3, Guidelines regarding the Form and Structure of National
Reports, which the Contracting Parties adopted during the 2nd Extraordinary Meeting in
May 2014.
A.2
Since the Fourth Review Meeting, FANR has granted to ENEC a licence to construct
the first two nuclear installations at the site named Barakah on the coast of the Arabian Gulf
approximately 264 km west of Abu Dhabi. The technology selected by ENEC is the APR-1400
advanced pressurised water reactor supplied by a team led by the Korea Electric Power
Company (KEPCO). FANR granted the construction licence on 17 July 2012 after completing
a thorough review and assessment of the application that ENEC submitted in December
2010.
FANR's review and assessment verified that the application contained sufficient information
to give reasonable assurance that the proposed facility will be constructed in accordance
with the safety requirements set forth in the Law and regulations. The site construction and
manufacture of components for the licensed installations is currently progressing in line
with the schedule milestones set by ENEC.
On 28 February 2013, ENEC submitted to FANR a further application for authorisation to
construct the third and fourth APR-1400 units at the Barakah site. FANR issued this
construction licence on 15 September 2014.
A.3
FANR has also continued to focus on development of regulations and guides for the
safety of waste management and has developed FANR-REG-26 "Predisposal Management of Radioactive Waste" which is ready for expert mission review and then to go out for stakeholders' comments, together with the regulatory guide FANR-RG-018. This regulation and guide will complement the existing regulations FANR-REG-11, for nuclear facilities and FANR-REG 24 for non-nuclear facilities which contains basic requirements on waste management. FANR-REG-24 has also been updated, integrating in the UAE Legislation the most advanced international recommendations in the field of Radiation Protection. Two other regulations are drafted FANR-REG-21 "Decommissioning of Facilities" and FANR-REG-27 "Disposal of Radioactive Waste". FANR-REG-22 "Decommissioning Trust Fund" is under development.
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Table A-4 presents an overview of the UAE program
Table A-4
Overview - UAE program
Long-term
Funding of
Planned facilities
Liability
management policy
Liabilities
practice /
Facilities
Spent fuel
The UAE has yet to
Onsite storage in
determine its policy for
Trust Fund (DTF)
Spent Fuel Pool (SFP)
long-term management of
ENEC plan for
Independent Spent
Installation (ISFSI)
See section
B.5, F4-F.6, F.8,
Nuclear fuel
Pre-disposal management
Funded as part of
Low Level Waste (LLW)
repository to be
established in UAE
See section
Long-term management
• Onsite storage
NORM Treatment and
nuclear fuel
options depend on origin
Disposal facility for one
and type of waste.
applicant is under
radioactive
See section
B.6, C.2, C.3, K.13,
Decommissioning is a
Regulated Activity in UAE
Trust Fund (DTF)
Nuclear Law; planning
required in requirement
for Nuclear Facility licence
applications (REG 06)
See section
B.5, F4-F.6, F.8,
• Return to the
New storage facility for
orphan sources has been
• Onsite storage
See section
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Section B. Policies and Practices
Article 32.1: Reporting
In accordance with the provisions of Article 30, each Contracting Party shall submit a national report to each review meeting of Contracting Parties. This report shall address the measures taken to implement each of the obligations of the Convention. For each Contracting Party the report shall also address its:
(i) spent fuel management policy (ii) spent fuel management practices (iii) radioactive waste management policy (iv) radioactive waste management practices (v) criteria used to define and categorize radioactive waste
Spent Fuel Management Policy
B.1
The UAE Policy Paper (In Annex B) sets out several important commitments that bear
on the development of the UAE's spent fuel policy. These commitments include the following;
Renouncing an intention to develop a domestic enrichment and reprocessing capability
and undertaking to source fuel from reliable and responsible foreign suppliers
Development as required, of a comprehensive waste management system that reflects
the highest standard of international practice and which does not include domestic reprocessing
These commitments are described in detail In the UAE Policy Paper section 2, pages 9 and
10 and were included in the first UAE National Joint Convention report. This is also
expressed in the UAE Nuclear Law Article (2.2).
B.2
The UAE Nuclear Law also enshrines the commitment to no domestic enrichment
and reprocessing and contains provisions related to spent fuel and radioactive waste
management policy (Chapter Eight: Radioactive Waste and Decommissioning).
B.3
In considering its spent fuel management strategy the UAE is striving to achieve a
suitable balance between keeping options open and establishing a sufficiently concrete planning basis. It will seek to take into account;
fuel cycle choices (fuel leasing, direct disposal or foreign reprocessing of spent fuel) the technologies that are foreseen for waste treatment, storage and disposal where waste management facilities might be located (independently or co-located
when activities must be initiated (as early as possible, technically optimized or
delayed for economic optimization) and for how long
The UAE is considering a number of scenarios including ‘domestic' scenarios, involving waste disposal facilities in the UAE and ‘external services' scenarios involving fuel leasing or
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foreign reprocessing, as well as ‘sharing' scenarios in which some waste management
activities or facilities are shared regionally or internationally. It is intended to establish a
‘roadmap' which will set out the main activities and critical decision points.
Spent Fuel Management Practices
B.4
The UAE does not yet have any spent fuel but ENEC has taken the following
measures for the management of spent fuel
The design of the Barakah NPP provides sufficient capacity in the spent fuel storage
pool for 20 years of operation for each plant.
ENEC intends to establish an independent spent fuel storage installation (ISFSI) to
support on-going operations. The ISFSI will be established before the spent fuel storage pool reaches capacity. A dry storage feasibility study has been conducted to identify the ideal location within the current site boundary for a future dry storage facility. The study also evaluated the existing and planned reactor site infrastructure, including the design of the spent fuel pool and the fuel handling area, to determine any design changes or improvements required at this stage of the project in order to allow safe and efficient transfer of the spent nuclear fuel. The study also evaluated the future haul path requirements for spent fuel movement from the reactor spent fuel pool to the ISFSI. The requirements and the recommendations of this feasibility study will be implemented and incorporated in the current development and construction of the Barakah NPP site.
In addition, ENEC is also looking at long-term spent fuel disposal options for different
Radioactive Waste Management Policy
B.5
In addition to the references to radioactive waste management in the Policy Paper as
stated above, Chapter 8 of the UAE Nuclear Law (Articles (40-42)) addresses issues of radioactive waste and decommissioning, where;
Article (40.1) affirms the responsibility of licensees to safely manage and store
radioactive waste from its generation until delivery to an entity designated by the UAE Cabinet to manage disposal of such material
Article (40.2) obliges the licensee to comply with duties and responsibilities for the
safe management of radioactive waste determined by the Authority
Article (40.3) states that the Board of FANR shall by detailed rules determine the
requirements, responsibilities and duties for the safe management of radioactive waste
Article (41.1) states that the UAE Cabinet shall issue a policy regarding long-term
management and disposal of spent fuel and nuclear waste and identify the entity in charge of implementing the policy. It also states that the spent fuel and radioactive waste will become property of the state from the time of its delivery to the state or to the entity designated by the Cabinet
Article (41.2) states that regulations shall specify terms and procedure for waste
delivery to the entity designated by the Cabinet, including waste which is not subject
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to delivery, and the regulation shall also specify time limits for the delivery and fees to be paid by the radioactive waste producers
Article (41.3) prohibits import of spent nuclear fuel and nuclear waste derived from
nuclear energy applications outside the UAE, for the purpose of long term storage or disposal in the UAE's lands and sites.
Article (42)
establishes a legal regime for decommissioning of nuclear
installations, including establishment by the UAE Cabinet of a Decommissioning Trust Fund to be financed through fees collected from licensees. The fees are to cover the costs of construction, operation and closure of a radioactive waste management facility, decommissioning costs, costs of regulatory oversight and for management of the Trust Fund.
The UAE adopts an approach to management of radioactive waste that derives from
the particular applications. This is described in the drafted FANR-REG-26 "Predisposal Radioactive Waste Management" and the corresponding FANR-RG-018;
Laboratory and medical waste can be discharged as non-radioactive waste when
decayed below clearance levels indicated in FANR-REG-24.
The clearance levels adopted by the UAE are the same as those in IAEA GSR Part 3. The licensees are required to send disused sources to their supplier or the
manufacturer. If return to manufacturer or reuse are not viable options, then the sources should be managed as radioactive waste and stored locally by the Licensee, at the conditions indicated by FANR, until UAE waste acceptance criteria for disposal are developed and published.
The UAE has developed an Orphan Source Strategy which will be presented at the
Treatment and disposal of Naturally Occurring Radioactive Material (NORM)
contaminated material and waste is assessed case by case. A NORM treatment and disposal facility license application is presently under review by FANR.
For FANR promulgated radioactive waste regulations and guides, see Sections E.8-E.9
Radioactive Waste Management Practices
B.7
Users of radioactive sources are required to return disused sources to the
manufacturer, however some licensees have legacy sources stored on their premises (See Section J). FANR Regulation FANR-REG-24, "Basic Safety Standards for Facilities and Activities involving Ionizing Radiation other than in Nuclear Facilities" has been issued which permits the clearance of radioactive material from regulatory control and systematizes the process of disposal of radioactive waste by the user. The UAE has 12 medical facilities dealing with nuclear medicine and radiotherapy generating small amounts of radioactive waste, usually with very short half-lives. These facilities temporarily store waste on their premises for a limited period until they decay to activity levels below the limits given in Table I-1 of Schedule 1 of FANR-REG-24. Then the waste is appropriately discharged.
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ENEC's activities related to radioactive waste management are outlined below:
ENEC is not currently generating any radioactive waste An internal assessment of different strategy options for radioactive waste storage
and disposal has been prepared.
Radioactive waste management at ENEC includes principles as:
o Minimization of volume of waste generated from Barakah NPP through
effective operations and the use of proven technology.
o Storage of low and intermediate level radioactive waste at the Barakah NPP
o Possible longer term radioactive waste storage through the construction of a
separate Low/Intermediate Radwaste Storage Building near the Barakah NPP.
Criteria used to define and categorize radioactive waste
B.9
The UAE Nuclear Law defines Radioactive Waste as "Waste that contains, or is
contaminated with, radionuclides at concentrations or activities greater than levels as established by the Authority". FANR-RG-018, Article (4) "Predisposal Radioactive Waste Management" classifies radioactive waste based upon the IAEA safety standard GSG-1 Classification of Radioactive Waste Safety Guide.
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Section C. Scope of Application
Article 3: Scope of application
1. This Convention shall apply to the safety of spent fuel management when the spent fuel
results from the operation of civilian nuclear reactors. Spent fuel held at reprocessing facilities as part of a reprocessing activity is not covered in the scope of this Convention unless the Contracting Party declares reprocessing to be part of spent fuel management.
2. This Convention shall also apply to the safety of radioactive waste management when the
radioactive waste results from civilian applications. However, this Convention shall not apply to waste that contains only naturally occurring radioactive materials and that does not originate from the nuclear fuel cycle, unless it constitutes a disused sealed source or it is declared as radioactive waste for the purposes of this Convention by the Contracting Party.
3. This Convention shall not apply to the safety of management of spent fuel or radioactive waste
within military or defence programmes, unless declared as spent fuel or radioactive waste for the purposes of this Convention by the Contracting Party. However, this Convention shall apply to the safety of management of spent fuel and radioactive waste from military or defence programmes if and when such materials are transferred permanently to and manage within exclusively civilian programmes.
4. This Convention shall also apply to discharges as provided for in Articles 4, 7, 11, 14, 24 and 26.
Spent Fuel at Reprocessing Facilities
C.1
A declaration of reprocessing as part of spent fuel management will be considered if
the UAE determines that reprocessing of spent fuel outside the UAE is part of its long-term
management of spent fuel.
Naturally occurring radioactive material
C.2
The UAE does not declare waste that contains only naturally occurring radioactive
material and that does not originate from the nuclear fuel cycle as radioactive waste for the
purpose of the Joint Convention, pursuant to Article 3(2), as long as the Naturally Occurring
Radioactive Material (NORM) is stored at the NORM generators without treatment.
C.3
FANR has received, in December 2012 an application from one of the oil and gas
producers in UAE, to construct a treatment and disposal facility for the NORM generated
during oil and gas producing processes. The NORM treatment facility is planned to include
activities such as decontamination, volume reduction, NORM handling and immobilization
of NORM into packages suitable for final disposal in a landfill. The application is under
review by FANR. The NORM waste in this planned treatment and disposal facility is declared
as radioactive waste for the purpose of the Joint Convention pursuant to Article 3(2).
Military or defence programmes
C.4
No spent fuel or radioactive waste from military or defence programs is declared as
spent fuel or radioactive waste for the purpose of the Convention pursuant to Article 3(3).
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Discharges
C.5
Regulatory requirements have been established to ensure that radioactive discharges shall
be limited and consistent with international norms and standards. This is included in Sections G.4, G.16 and H.24 of this report.
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Section D. Inventories and Lists
Article 32.2: Reporting
2. This report shall also include:
(i) a list of the spent fuel management facilities subject to this Convention, their location, main
purpose and essential features
(ii) an inventory of spent fuel that is subject to this Convention and that is being held in storage
and of that which has been disposed of. This inventory shall contain a description of the material and, if available, give information on its mass and its total activity
(iii) a list of the radioactive waste management facilities subject to this Convention, their
location, main purpose and essential features
(iv) an inventory of radioactive waste that is subject to this Convention that:
(a) is being held in storage at radioactive waste management and nuclear fuel cycle facilities (b) has been disposed of (c) has resulted from past practices
This inventory shall contain a description of the material and other appropriate information
available, such as volume or mass, activity and specific radionuclides;
(v) a list of nuclear facilities in the process of being decommissioned and the status of
decommissioning activities at those facilities
Spent Fuel Management Facilities and Inventory of Spent Fuel
D.1
At this stage of the UAE civil nuclear energy program, the UAE has no spent fuel or
spent fuel management facilities.
Radioactive Waste Management Facilities
D.2
Currently there are no radioactive waste management facilities (as defined in the
Joint Convention) in the UAE. One storage facility for orphan sources has already been
identified, and is under development.
Inventory of Radioactive Waste
D.3
Radioactive sources are used in the UAE in a range of industrial and medical
applications. FANR did a waste survey in 2011 which was presented at the JC meeting in
May 2012. The results of the survey are provided in Annex A.1.
D.4
FANR is in the process of the first re-licensing of all users of Regulated Material (this
re-licensing of radioactive materials' and radiation generators' licensees will be repeated
every three year). During the re-licensing process, FANR requests licensees to present a re-
take agreement with the supplier or manufacturer when the sources becomes disused.
FANR has established its Regulatory Authority Information System (RAIS) which includes all
licensed radioactive sources and disused radioactive materials stored at the licensee's
premises.
D.5
The UAE has 12 medical facilities dealing with nuclear medicine and radiotherapy
generating small amounts of radioactive waste with very short half-lives. These facilities
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store this waste on their premises for a limited period until they decay to activity levels
below the limits given in Table I-1 of Schedule 1 of FANR-REG-24. Then the waste is
appropriately discharged.
Decommissioning of Nuclear Facilities.
D.6
There are no nuclear facilities in the UAE at present.
In July 2012, FANR completed its review of ENEC's construction licence application for the first nuclear power plants in the UAE, Barakah Units 1 and 2 and documented its findings in a Safety Evaluation Report (SER). The SER summary is available on FANR's web site, On 17 July 2012, the FANR Board of Management accepted the findings and recommendations of the FANR staff and decided to issue the construction licence for Barakah Units 1&2. Construction of the first two units is progressing according to the schedule set by ENEC. A construction licence for Units 3 and 4 was issued on 15 September 2014 and safety-related construction has commenced. ENEC plans to submit to FANR an operating licence application that will be based on the submissions for the reference plant that previously have been reviewed and have resulted in an operating licence decision by the authorities of the Republic of Korea. The operating licence application will include the Final Safety Analysis Report (FSAR) and other supporting documents required by FANR for review. The FSAR will include complete information concerning facility operation, including the organizational structure, responsibilities and authorities, managerial and administrative controls to be used to assure safe operation, plans for start-up testing and initial operations, plans for conduct of normal operations, including maintenance, surveillance, and periodic testing, plans for coping with emergencies, decommissioning plan and proposed technical specifications. The FSAR will be the principal document upon which FANR will base its review and assessment to support a future decision to issue an operating licence. FANR is currently developing regulation FANR-REG-21 "Decommissioning of Facilities" which establishes the safety requirements for all aspects of NPP decommissioning from the siting and design of a Facility to the termination of the Licence. The decommissioning plan for the nuclear power plant, to be submitted by ENEC as part of the FSAR, is required to meet the requirements of FANR-REG-21 "Decommissioning of Facilities".
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Section E. Legislative and Regulatory System
Article 18: Implementing Measures
Each Contracting Party shall take, within the framework of its national law, the legislative, regulatory and administrative measures and other steps necessary for implementing its obligations under this Convention.
Steps to Implement Obligations
E.1
The UAE has established the legislative framework needed to implement its
obligations under the Joint Convention, principally through the UAE Nuclear Law.
Articles (11), (38), and (39) of the UAE Nuclear Law empower the FANR Board of
Management to issue regulations and regulatory guides, which are required for FANR's
operation, "taking into consideration comments from stakeholders, information made
available by experts, and internationally recognized standards and recommendations, such
as IAEA standards."
E.2
FANR has established within its Integrated Management System (IMS) a process for
establishing and revising regulations and guides that includes provisions for consultation
with stakeholders and the public, and review and incorporation of their comments.
E.3
The relevant IAEA safety requirements have served as the basis for many of the
regulations related to nuclear installations. FANR contributes to the development of the
IAEA Safety Standards through membership on the Standards Committees and the
Commission on Safety Standards (CSS). Through its participation on the Committees, FANR
has also observed the actions taken by the IAEA to strengthen its safety requirements
following the accident at Fukushima-Daiichi.
E.4
An Integrated Regulatory Review Service (IRRS) Mission was conducted by the IAEA
in December 2011, covering the UAE regulatory framework for all nuclear activities
regulated by FANR. The UAE reported on the relevant outcomes of this IRRS mission at the
Fourth Review Meeting in May 2012. The IRRS mission to the UAE examined the status of
FANR's regulations and confirmed that the regulatory framework development is
appropriate for this stage of the program. This mission also took into account the lessons
learned up to that time from the accident at the Fukushima Daiichi Nuclear Power Station.
The IRRS mission is discussed in more detail in Annex D.
Article 19: Legislative and Regulatory Framework
1. Each Contracting Party shall establish and maintain a legislative and regulatory framework to
govern the safety of spent fuel and radioactive waste management.
2. This legislative and regulatory framework shall provide for:
(i) the establishment of applicable national safety requirements and regulations for radiation
(ii) a system of licensing of spent fuel and radioactive waste management activities (iii) a system of prohibition of the operation of a spent fuel or radioactive waste
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management facility without a licence
(iv) a system of appropriate institutional control, regulatory inspection and documentation
(v) the enforcement of applicable regulations and of the terms of the licences; (vi) a clear allocation of responsibilities of the bodies involved in the different steps of spent
fuel and of radioactive waste management
3. When considering whether to regulate radioactive materials as radioactive waste,
Contracting Parties shall take due account of the objectives of this Convention.
The establishment of applicable national safety requirements and
regulations for radiation safety
E.5
Article (11)(4) of the UAE Nuclear Law gives the Board of Management of FANR the
power to establish, develop or adopt regulations and guidelines upon which its regulatory
actions are based, including the objective of protecting ‘individuals, society and the
environment from radiation hazards both for the present and in the future.'
E.6
Article (38) of the UAE Nuclear Law specifies that the Board shall issue the
regulations specifying the requirements which all operators must comply with and follow.
E.7
The UAE Nuclear Law also defines the Regulated Activities for which a Licence is
needed. It defines Radioactive Waste as "waste that contains, or is contaminated with,
radionuclides at concentrations or activities greater than the levels as established by the
Authority".
E.8
FANR has 18 Regulations and 16 Regulatory Guides of which 5 are in draft form. Five of the
regulations contains requirement on management of radioactive waste;
FANR-REG-11, "Radiation Protection and Predisposal Radioactive Waste
Management for Nuclear Facilities;"
FANR-REG-24, "Basic Safety Standards for Facilities and Activities involving Ionizing
Radiation other than in Nuclear Facilities"
FANR-REG-21, "Decommissioning of Facilities" (draft) FANR-REG-26, "Predisposal Management of Radioactive Waste" (draft) FANR-REG-27, "Disposal of Radioactive Waste" (draft)
For a complete list of FANR Regulations and Guides see Annex B and. The
FANR Regulation and Guide development plan is also accessible on FANR web site:
E.9
FANR-REG-26 "Predisposal Management of Radioactive Waste" is a complement to
FANR-REG-11, "Radiation Protection and Predisposal Radioactive Waste Management for Nuclear Facilities", and the revised FANR-REG-24, Version 1 "Basic Safety Standards for Facilities and Activities involving Ionizing Radiation other than in Nuclear Facilities". The revised FANR-REG-24 contains some needed clarifications identified during the IRRS mission in 2011.
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FANR-REG-26 is supported by FANR-RG-018 "Predisposal Radioactive Waste Management" which contains information on waste classification, generation of radioactive waste, treatment and conditioning of radioactive waste, storage and safety assessment and safety case. (See definition in section G.15) The guide will assist FANR's Licensees conducting activities involving the pre-disposal management of radioactive waste (including spent and disused sealed sources associated with the use of radioactive material in medicine, industry, research, agriculture and education as well as waste arising from the operation of nuclear facilities) for implementing the regulatory requirements. In annexes the guide also provides specific guidance for predisposal management of disused sealed sources (low and higher activity), laboratory and medical waste and residues from industrial processing. FANR-REG-26 and FANR-RG-018 are expected to be approved by the FANR board and FANR Director General respectively prior to the fifth review meeting. FANR-REG-27 "Disposal of Radioactive Waste" will establish requirements for radioactive waste disposal in accordance with IAEA SSR-5 "Disposal of Radioactive Waste" which includes:
Safety requirements related to planning for the disposal of radioactive waste. Requirement for the development, operation and closure of a disposal facility. Assurance of safety
A system of licensing of spent fuel and radioactive waste management
activities
E.10
The UAE Nuclear Law Articles 23 to 31 provides requirements for granting,
revocation, and suspension of licences. A licence is required to carry out any Regulated
Activity defined in Article (25) including spent fuel and radioactive waste management
activities. Regulated Activities include those related to Nuclear Facilities (according to the
definition in the Law, a Nuclear Facility includes a Radioactive Waste Repository) and
dealings with Regulated Material, which includes radioactive waste.
E.11
Article (28) requires applicants for a licence to submit detailed evidence of safety
that shall be reviewed and assessed by FANR in accordance with defined procedures.
E.12
Article (6) gives exclusive authority to FANR for issuing licences to practice any of the
Regulated Activities in the UAE and permits FANR to impose conditions in licences.
E.13
Following review and assessment of a licence application for a Regulated Activity
with Regulated Material, FANR determines whether to issue a licence, a licence with
conditions, or to refuse a licence and record the basis for the decision.
E.14
The licensing process for spent fuel and radioactive management activities in nuclear
power plants is an integrated part of the licensing of nuclear facilities as described below.
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Assessment of Safety
Overview of the UAE's arrangements and regulatory requirements to perform
comprehensive and systematic safety assessments
Article (5) of the UAE Nuclear Law gives powers to FANR to establish the requirements for
systematic Safety Assessments and Periodic Safety Reviews. Article (28) of the Law makes it
clear that detailed evidence of safety is required at all relevant licensing stages of any
nuclear installation. Articles (29) and (43) require the licensee to perform safety
assessments over the lifetime of the nuclear facility, address any deficiencies, and provide
FANR with any information relevant to the Authority's regulatory responsibilities. Article
(32) requires review and assessment of the licensee or applicant at every stage of the
regulatory process.
Regulation FANR-REG-06, "Application for a Licence to Construct a Nuclear Facility," and
regulation FANR-REG-14, "Application for a Licence to Operate a Nuclear Facility," define an
Independent Safety Verification (ISV) as, "A written verification performed by suitably
qualified and experienced individuals, who did not participate in the original Safety
Assessment, to determine whether the approach taken in conducting such Safety
Assessment was reasonable and in accordance with international best practice." Each of
these regulations requires that an ISV report be provided as part of the licence application
request describing all proposed departures from or changes to the reference design.
Assessment of safety through the licensing process
Article (25) of the UAE Nuclear Law requires that a licence be obtained prior to engaging in
any "Regulated Activity" which include selection of a site for, preparation of a site for,
construction, commissioning and operation of a nuclear facility.
Each licence application is required to meet all applicable legal and regulatory requirements.
FANR is required by Law to conduct a thorough review and assessment of licence
applications to verify that the relevant objectives, principles and criteria are met, and to
satisfy itself that the available information demonstrates the safety of the facility or activity.
Following its review and assessment, FANR is empowered to grant a licence, grant a
conditional licence, or refuse a licence request. Article (28) of the Law stipulates that the
FANR formally records the basis for its licensing decisions.
FANR has established in its management system a process consistent with the UAE Nuclear
Law and the relevant IAEA safety requirements for assessing applications for licences
related to the construction and operation of a nuclear facility. The main steps in the process
comprise the receipt and acknowledgement of the application; review and assessment of
the application; issuing requests for additional information from the applicant where
necessary; preparation of a safety evaluation report; and a decision on licensing by the
Board of Management. Supporting procedures and instructions detail the methods and
criteria to be applied by reviewers.
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A system of prohibition of the operation of a spent fuel or radioactive waste
management facility without a licence
E.15
Article (23) of the UAE Nuclear Law prohibits any person from conducting any
‘Regulated Activity' in the UAE unless licensed to do so by FANR. Regulated Activity includes
the siting, construction, operation and decommissioning of Nuclear Facilities, including
radioactive waste repositories, and activities with ‘Regulated Material', which includes
radioactive waste. Articles (60) to (62) of the UAE Nuclear Law establish criminal penalties
for carrying out Regulated Activity without a licence.
A system of appropriate institutional control, regulatory inspection and
documentation and reporting
E.16
The UAE Nuclear Law Articles (32-37) provides requirements on inspection and
control of licensee activities. Article (35) requires FANR to establish a planned and
systematic inspection programme. Article (36) requires FANR to conduct inspections
covering all areas of regulatory responsibility to ensure that the operator is in compliance
with the law, regulations and licence conditions. In undertaking inspections, FANR is
required to take account of the activities of suppliers of services and products to the
operator. Article (5.8) provides FANR with the power to enter sites and facilities to carry out
inspections.
E.17
FANR has established within its Integrated Management System (IMS) a process
consistent with the requirements of the UAE Nuclear Law and the relevant IAEA safety
requirements for inspection of licensees' activities to verify compliance with the UAE
Nuclear Law, FANR regulations, and the licence conditions. Supporting procedures and
instructions detail the methods that are to be applied by inspectors in different areas
including radioactive waste management.
E.18
FANR has reviewed and accepted the description of the construction inspection and
test programme given in the PSAR during its review of ENEC's application for a construction
licence, as noted in section F.17.
E.19
Following the issuance of the construction licence, FANR mobilised its inspection
team to verify that ENEC's construction activities comply with FANR requirements and the
terms and conditions of the licence. The UAE Nuclear Law gives FANR powers to inspect the
activities of licensees and their contractors. According to Article (34) of the UAE Nuclear Law
the licensee remains responsible to FANR even if certain activities are carried out by its
contractors. FANR has established within its Integrated Management System (IMS) a process
consistent with the requirements of the UAE Nuclear Law and the relevant IAEA safety
requirements for inspection of licensees' activities. Supporting procedures and instructions
detail the methods that are to be applied by inspectors.
E.20
In order to effectively deliver its inspection programme, FANR has set a formal
qualification standard for its inspectors. The inspector qualifications include theoretical (classroom) and practical (on-the-job) training in basic and applied nuclear technology, management systems, quality assurance and safety culture, inspection and enforcement
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procedures, and training in legal procedures by the UAE Ministry of Justice. 48 FANR
inspectors are currently qualified, supported by other FANR subject matter experts and
contractors. See section E.42.
FANR has formulated annual inspection programmes covering the activities of ENEC and its
prime contractor and major suppliers related to engineering, procurement and site
construction. The annual inspection programmes focuses on the requirements for the
management system and quality assurance programme to verify that the controls specified
by the licensee comply with the requirements and are implemented in the supply chain. The
specific inspection areas are selected based on ranking criteria which include measures of
risk significance and feedback from previous inspections.
E.21
The issuance of the construction licence in 2012 for units 1 and 2 of the Barakah
Nuclear Power Plant increased the demands for regulatory inspection in 2013 and in coming
years to verify that the licensee is carrying out its construction activities safely and in
accordance with FANR's requirements. FANR has formally qualified an inspection workforce
through a combination of training and on-the-job experience, and has also engaged
Technical Support Organisations (TSOs) to reinforce its in-house resources to match demand
in this important area of its regulatory programme.
FANR carried out two inspections on ENEC's management system in 2013 with a focus on
quality assurance against the criteria in FANR-REG-01. During 2013, 13 site inspections on
the construction works were carried out, and eight inspections were conducted on
equipment vendors located overseas in Korea and the USA. The inspections are documented
in the inspection reports summarized on the FANR web site. The findings show that ENEC
and its suppliers are generally in conformance with FANR requirements. All adverse findings
were evaluated to be of low safety significance. ENEC and the relevant suppliers were
required to take action to correct any deficiencies observed during the inspections. FANR
inspectors follow up on the implementation of corrective actions.
E.22
From 26 to 28 November, 2012 FANR hosted an IAEA workshop at FANR's
headquarters in Abu Dhabi, UAE to obtain support in developing its inspection programme
for the construction of the nuclear power plant. During three days of the workshop, experts
from the IAEA, Finland, France and the USA delivered presentations regarding lessons
learned during construction of nuclear power plants. Approximately 40 participants from
FANR, ENEC, and other UAE government entities participated in the workshop. The
workshop provided insights to further enhance the FANR inspection programmes at the
Barakah NPP and its vendors.
The enforcement of applicable regulations and of the terms of the licences
E.23
Article (5.17) of the UAE Nuclear Law gives FANR the power to undertake
enforcement actions, which are defined to include corrective actions, written warnings, revocation of a licence, and administrative penalties and fines. Article (36.2) empowers FANR to take enforcement action compelling the operator to take actions necessary to remediate any breach. Article (36.3) empowers FANR itself to remedy a breach if the operator does not do so. In such cases, the operator would bear the necessary costs of such
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an intervention. Article (37) obliges the operator to comply with FANR decisions and to
remedy any breach, undertake an investigation related to the breach, and take any
measures necessary to prevent a recurrence.
E.24
Articles (57-64) of the UAE Nuclear Law provide provisions for civil liabilities and
criminal penalties for various offences related to the requirements of the UAE Nuclear Law.
To date, no significant enforcement actions pursuant to the above authorities have been
necessary with regard to applicants for nuclear facility licences or users of Regulated
Material.
A clear allocation of responsibilities of the bodies involved in the different
steps of spent fuel and of radioactive waste management
E.25
As noted in section B.2 of this National Report, Chapter 8 of the UAE Nuclear Law
(Article (40-42)) addresses issues of radioactive waste and decommissioning, where:
Article (40.1) affirms the responsibility of licensees to safely manage and store
radioactive waste from its generation until delivery to an entity designated by the UAE Cabinet to manage disposal of such material.
Article (40.2) oblige the licensee to comply with duties and responsibilities
determined by the Authority.
Article (40.3) requires FANR to adopt rules for safe management of radioactive
Article (41.1) provides that the UAE Cabinet will issue a policy regarding long-term
management of spent fuel and nuclear waste. It also states that the spent fuel and radioactive waste will become property of the state from the time of its delivery to the state or to the entity designated by the Cabinet.
Article (41.2) states that regulations shall specify terms and procedure for waste
delivery to the entity designated by the Cabinet, including waste that is not subject to delivery, and the regulation shall also specifies time limits for the delivery and fees to be paid by the radioactive waste producers.
Other authorities concerned with environmental impact assessment, local planning, waste
management and other governmental activities will be involved as appropriate as the UAE's
overall strategy is developed.
Whether to regulate radioactive materials as radioactive waste
E.26
The UAE is following IAEA safety standards and guidance in making these decisions.
The UAE Nuclear Law defines Radioactive Material as "material designated by the Authority as being subject to Regulatory Control because of its radioactivity". The activity levels designated by the Authority as being subject to Regulatory Control because of its radioactivity are clarified in FANR-REG-24 Article (2) item 3 using IAEA GSR-Part 3 Schedule I. The definition of Radioactive Waste in the UAE Nuclear Law is "Waste that contains, or is contaminated with, radionuclides at concentrations or activities greater than levels as
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established by the Authority". These levels are the same levels as for regulated material as
described in FANR-REG-24 Article (2) item 3 using IAEA GSR-Part 3 Schedule I.
FANR accepts the definition in IAEA Nuclear Safety and Security Glossary, where Waste is
defined as "Material for which no further use is foreseen."
Material which will not be used anymore and contaminated with radionuclides in
concentrations or activities above those levels is designated as ‘radioactive waste'.
FANR-REG-11 and FANR-REG-24 states basic requirements for radioactive waste from
nuclear facilities and other facilities respectively and FANR-REG-26 addresses pre-disposal
management of radioactive waste from all facilities.
Article 20: Regulatory Body
1. Each Contracting Party shall establish or designate a regulatory body entrusted with the
implementation of the legislative and regulatory framework referred to in Article 19, and provided with adequate authority, competence and financial and human resources to fulfill its assigned responsibilities.
2. Each Contracting Party, in accordance with its legislative and regulatory framework, shall take
the appropriate steps to ensure the effective independence of the regulatory functions from other functions where organizations are involved in both spent fuel or radioactive waste management and in their regulation.
Establishment of the Regulatory Body
E.27
FANR is the federal governmental agency designated as the Regulatory Body which
gets its powers from the UAE Nuclear Law. Chapter 2, Articles (4–9) of the UAE Nuclear Law establishes FANR as the regulatory body to implement the legislative and regulatory framework.
Article (4) establishes FANR as a public, federal organisation with an independent
balance sheet, an independent legal personality, full legal competence and financial and administrative independence. It states the aims of FANR as the assurance of safety, security and radiation protection within the UAE nuclear programme with the development of the nuclear sector towards only peaceful purposes
Article (5) gives power to FANR to determine all matters relating to the regulation of
the nuclear and radiological sectors in regard to safety, nuclear safety, nuclear security, radiation protection and safeguards. FANR must also implement obligations under relevant international instruments entered into by the UAE. This Article lists the powers of FANR in 33 sub-Articles
Article (6) gives FANR exclusive jurisdiction over the licensing of ‘Regulated Activities'
Article (7) requires FANR to co-operate with relevant government including in
relation to radioactive waste
Article (8) authorizes FANR to investigate potential breaches of the UAE Nuclear Law
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Article (9) requires FANR to maintain the highest standards of transparency in its
regulatory activities while allowing it to protect confidential information.
Chapter 3, Articles (10-17) of the UAE Nuclear Law sets out provisions on the
management of FANR.
Article (10) establishes the FANR Board to manage the organization, Article (11) establishes the general authorities and functions of the Board including
that it establishes the general policy of FANR, adopts its budget and organisational structure, and issues the range of regulations and requirements needed for FANR's operations and functions
Article (12) sets forth conditions of Board membership Article (13) identifies the grounds on which Board members may be replaced Article (14) provides for the appointment of a Director General to manage FANR and
oversee its financial, administrative and technical affairs
Article (15) establishes that the Director General manages FANR's business and
oversees its financial, administrative and technical affairs under the Board of Management control. It sets out the duties of the Director General in nine sub articles, including that the Director General reviews all licence applications and makes appropriate recommendations to the Board
Article (16) limits the grounds on which the Director General may be replaced Article (17) authorizes FANR to appoint employees.
Chapter 4, Articles (18-22) of the UAE Nuclear Law deal with FANR's financial affairs.
Article (18) gives FANR the powers to manage its finances and identifies the means
of funding for FANR as: funding allocated by Government; income generated from its functions (fees); and other income that is accepted and that does not conflict with FANR's objectives
Article (19) establishes the dates of the fiscal year for FANR financing Article (20) makes FANR subject to UAE tender and procurement laws and applicable
financial and auditing regulations
Article (21) grants FANR exemption from UAE taxes Article (22) provides that the FANR Board will appoint an independent auditor to
report on the Authority's financial affairs.
Status of the Regulatory Body
E.30
The UAE Nuclear Law clearly establishes FANR as the independent government body
charged with the regulation and licensing of all nuclear activities within the UAE, which
includes the siting, construction, and operation, and decommissioning of Nuclear Facilities
as well as the regulation of radioactive materials and radiation sources used in medical,
research, oil exploration, and other industries. FANR is the sole decision-maker in licensing,
and its decisions are not subject to any external review. FANR is independent of ENEC and
any other entity charged with promotional responsibilities.
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Organisation and Staffing; Financial Resources
E.31
FANR Board Members are appointed for a renewable fixed term and can only be
removed by a resolution of the Cabinet for defined reasons (Article (13)). Board Members
are forbidden by law from engaging directly or indirectly in the conduct of any Regulated
Activity and must not have any personal interest that conflicts with the interests of FANR.
E.32
The FANR Board of Management exercises FANR's legal powers. The Board
comprises nine Emirati citizens, including the Chairman and Deputy Chairman, who are
appointed for a term of three years by resolution of the Cabinet. The Director General leads
the FANR staff organisation.
E.33
FANR has created two main divisions in the organisation to fulfill its responsibilities:
Administration and Operations. The Administration Division includes the Departments of Administration and Finance, Government Communication, Information & Communications Technology, and Human Resources; the Operations Division includes the Departments of Nuclear Safety, Radiation Safety, Nuclear Security, Safeguards, and Education and Training. FANR currently employs about 170 persons. The organisation chart is shown in Figure E.33.
Figure E.33 – FANR Management Organisation Chart
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FANR's budget is set by its Board of Management. From 2014, FANR's budget has
principally ben funded by licence fees, particularly the licence fees for nuclear facility
licences (90% of approved budget). FANR manages its financial resources according to the
applicable financial and auditing regulations within the UAE. The overall budget provided
has been adequate to enable FANR to carry out all of its significant regulatory
responsibilities over the reporting period.
E.35
The Chairman of the Board is required by the UAE Nuclear Law to submit a report, at
the end of each financial year, to the Minister of Presidential Affairs. The Board is also
required by law to submit a set of audited accounts to the Cabinet for endorsement. As
reflected in Chapter 4 of the UAE Nuclear Law discussed earlier, FANR has also been assured
of having sufficient, predictable and autonomous financial resources to fulfill its
responsibilities independently.
E.36
The reporting structure within the UAE government, its legal and financial
independence, the requirement for transparency, and its technical competence are factors
that demonstrate that FANR is effectively independent of other organisations concerned
with the promotion or utilisation of nuclear energy.
Integrated Management System
E.37
As recommended by IAEA publications on safety requirements and guidance, FANR
has developed and is implementing an Integrated Management System (IMS) that is tailored specifically to its Regulator role. The IMS includes a set of interacting processes that address the objectives and requirements of the organisation. Elements included in the IMS are the structure, resources, and processes of the core business areas of nuclear regulation, licensing and inspection, as well as corporate management and support functions. The early establishment of the integrated management system has helped FANR to deliver its functions effectively and support the development of a strong safety culture. Figure E.37 depicts the processes in the FANR IMS.
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Figure E.37 – FANR Integrated Management System Process
Human Resources and Knowledge Management
E.38
FANR has recruited a core team of experienced international technical personnel to
assist FANR in performing its responsibilities. FANR plans to maintain the core team and
develop a group of skilled UAE nationals in key areas through the National Capacity Building
Programme, (NCBP) which includes development of programmes for education and training,
college graduates and new engineers being trained overseas (206 young Emiratis studying
for bachelor's and master's degrees in nuclear subjects ), and specialized, individual training
plans. Individual Development Programmes (IDPs) will be prepared for specific positions in
the developing workforce. Over the long-term, FANR will establish its own in-house nuclear
expertise as provided by UAE nationals with support from international experts.
E.39
FANR has made significant progress in recruiting a qualified and capable workforce
over the past five years. The FANR staff as of the date of this report numbers approximately
170 persons. Fifty-four per cent of the employees are Emirati citizens. The balance of the
staff comprises expatriates with nuclear experience recruited from 23 countries around the
world. The depth and breadth of expertise embodied within this team has been
instrumental in FANR's achievements to date.
E.40
Efforts are being made to retain in-house expertise and expand the workforce to
include a growing complement of Emirati nationals. In areas where technical knowledge is still being developed, FANR has contracted with Technical Support Organisations (TSOs). The role of TSOs includes the preparation of regulatory documents (regulations, regulatory guides and review procedures), the conduct of expert reviews in selected areas, and participation in inspection activities until such time as educated and qualified Emiratis can
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fulfill that role. FANR takes ownership of all technical reviews including those where TSOs
provide support.
E.41
FANR is in the process of assuring that significant activities involving the generation
and use of knowledge unique to the nuclear sector are being systematically identified and developed to ensure the sustainability of such knowledge from in-house sources. A Knowledge Management (KM) programme will comprehensively address the knowledge, experience and expertise generated in the regulatory, technical, scientific, administrative, legal and managerial areas. Implementation of these activities by FANR has already begun. The objectives of the KM program include:
Mitigate the risk of knowledge loss due to employees' mobility; Make available knowledge and experience that enhances the quality of collaboration
and increases the effectiveness and efficiency of the regulatory body; and
Assure sustainability of the UAE nuclear program through effective nuclear
knowledge transfer from one generation to another.
Having successfully recruited a workforce to meet near-term demands, FANR's
human resource strategy for long-term sustainability concentrates on developing Emirati nationals to take increasingly responsible positions in the regulatory body, while retaining an appropriate cadre of international experts. FANR complements its in-house training programmes through collaboration with ENEC, Khalifa University, the IAEA and other partner institutions in a national programme of capacity building which offers to citizens a range of education, training and development opportunities in the UAE and overseas. Until now (July 2014) FANR has achieved the following: Scholarships
FANR supported with ENEC and Khalifa University a scholarship program in Nuclear
Engineering. Two employees joined FANR during 2012 from this program.
A total of 14 staff members graduated from Liverpool John Moores University and
Risktec programme in Risk and Safety Management. Eight of them got a Master and six has got a Certificate. Two ladies completed their master degree in 2013.
One staff member was sent by FANR to study for a Master in Science in Radiation
and Environmental Protection at the University of Surrey, UK.
Three staff members were sent to KINS Korea Advanced Institute of Science and
technology (KAIST) for International Master Degree program in Nuclear Safety. One lady is there now doing her master.
FANR has sent 23 of its staff members to a four-month-long Gulf Nuclear Energy
Infrastructure Institute (GNEII) programme covering safety, security and safeguards, established in cooperation with Khalifa University, Sandia National Laboratories, and Texas A&M University. Nine of the staff members completed the course in 2013 and 2014.
Internships The internship programme gives young graduates exposure to the daily work of FANR and opportunities to be part of the team and learn from senior staff. Interns accompany professionals and senior management within FANR, gaining exposure to meetings and contributing to work. Until today (July 2014) FANR has had five interns that spent their internships in both the Operations and Administration Divisions.
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Employee Development Program
This employee development programme is designed to support FANR employee's
development by equipping them with the knowledge and skills needed to perform their
roles and responsibilities in FANR.
The programme modules cover basic, intermediate and advanced skills following IAEA
recommendations on competencies needed by the regulatory body.
Both Emirati and expatriate employees have attended numerous in-house training and
external courses covering technical skills, personal skills and management and leadership
topics. In-house training courses are delivered by staff experts and external consultants
coordinated by the Education and Training Department.
FANR has developed formal qualification standards for safety assessors and inspectors. The
Inspector Qualification Committee has until now (July 2014) qualified 48 inspectors from the
Operations Division. Some of the qualified inspectors are currently working on verifying the
safety of nuclear installations, supported by FANR specialists and contractors. The number
of inspectors is budgeted to grow in the future in line with progress of the construction and
commissioning of the nuclear facility.
E.43
Several projects and initiatives have been launched under this programme. This
includes, for example, formalizing the KM process within the Integrated Management
System, collecting "Travel Reports" in order to share knowledge about different events that
will be a reference for future generations, "video capturing" of notable presentations, and
development of a technical library. An IAEA preparatory mission was hosted in October
2012 to give support to the KM programme, and provided a number of suggestions and
recommendations for improvement.
E.44
Human capacity development for the nuclear/non-nuclear sectors
FANR has, often in cooperation with IAEA, but also on its own, conducted workshops and
training courses in UAE where participants from different organizations in the UAE have
been attending. FANR has hosted regional and international workshops in the UAE. In the
period from 2012 until 2014 FANR has hosted (or will be hosting) 27 national, regional or
international workshops, not including the numerous national and local events where FANR
has held presentations to inform about FANR and FANR areas of regulation.
The participants have come from Ministries; other regulatory bodies as Health Authorities,
Environmental Authorities, Customs, Police, Military, municipalities, emergency related
organisations; oil and gas related companies; users of radioactive material; and waste
management organisations.
E.45
FANR has also supported the development of radiation safety training for workers in
non-nuclear licensed entities by presenting training for different users and positions following the guidance of IAEA Safety Report Series No. 20 and IAEA RS-G-1.4. The training requirements are posted on the FANR web site which also lists some available training entities, although these entities are not accredited by FANR.
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Section F. Other General Safety Provisions
Article 21: Responsibility of the License holder
1. Each Contracting Party shall ensure that prime responsibility for the safety of spent fuel or
radioactive waste management rests with the holder of the relevant licence and shall take the appropriate steps to ensure that each such licence holder meets its responsibility.
2. 2. If there is no such licence holder or other responsible party, the responsibility rests with the
Contracting Party which has jurisdiction over the spent fuel or over the radioactive waste.
Responsibility of the Licence Holder
F.1
The UAE Nuclear Law Article (40) states that persons holding licenses to possess
Regulated Material are responsible for the safe management and storage of radioactive
waste from its generation until its delivery to the entity designated by a decision of the
Cabinet for the purpose of disposal. That entity would also need to be licensed by FANR to
deal with the radioactive waste and to establish a radioactive waste repository (defined as a
Nuclear Facility).
F.2
The UAE Nuclear Law Article (43) also makes clear that the licensee is responsible for
all steps necessary to reduce the risk of an accident to a level that is as low as reasonably
achievable, and that the licensee must ensure that there is a management system in place
and adequate financial and human resources to ensure nuclear safety. This also applies to
licensees who are responsible for the safety of spent fuel and radioactive waste
management.
Article 22: Human and financial resources
Each Contracting Party shall take the appropriate steps to ensure that: (i) qualified staff are available as needed for safety-related activities during the operating lifetime
of a spent fuel and a radioactive waste management facility
(ii) adequate financial resources are available to support the safety of facilities for spent fuel and
radioactive waste management during their operating lifetime and for decommissioning
(iii) financial provision is made which will enable the appropriate institutional controls and
Resources
F.3
The UAE does not currently have any spent fuel or radioactive waste management
facilities. However, the text below discusses how UAE is complying with JC Article 22 for the
planned Barakah Nuclear Power Plant. Facilities for spent fuel and radioactive waste
management will be reviewed similarly.
F.4
FANR-REG-06, "Application for a Licence to Construct a Nuclear Facility," and the
recently approved regulation FANR-REG-14, "Application for a Licence to Operate a Nuclear Facility," mandate that applicants demonstrate projected financial and human resource
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requirements for the proposed nuclear project and provide details regarding their financial
and technical qualifications to complete the proposed activities in accordance with nuclear
safety principles and requirements. Additionally, FANR-REG-14 requires applicants to
address the adequacy of decommissioning funding and the adequacy of plans for
radioactive waste management. FANR also issued FANR-RG-001, "Content of Nuclear Facility
Construction and Operating Licence Applications" to provide guidance on implementation of
these regulations. ENEC submitted construction license applications through the
preparation of a preliminary safety case for Barakah Units 1 & 2, and later for Units 3 & 4,
both in accordance with the requirements of FANR-REG-06 and under the guidance of
FANR-RG-001 and international guidance (including from the IAEA and USNRC). ENEC is
currently preparing the final safety case which includes more detailed and final design
information, for the purpose of submitting the Operating License Application for Units 1 & 2.
This is being prepared under the guidance provided in FANR-RG-001 and to meet the
requirements of FANR-REG-14.
F.5
The UAE Nuclear Law Article (42) requires that the operator of a nuclear facility must
pay fees into a "Decommissioning Trust Fund" (DTF). The fees are to cover the costs for:
construction, operation and closure of a radioactive waste management facility;
decommissioning the nuclear facility; regulatory oversight; and management of the trust
fund. It is planned that regulations establishing the decommissioning Trust Fund will be
completed by the time of commissioning of the first Barakah NPP Unit. ENEC has done some
preliminary cost estimates for decommissioning in anticipation of FANR-REG-22,
"Decommissioning Trust Fund."
F.6
Draft regulation FANR-REG-21, "Decommissioning of Facilities" mandate that the
application for an operating license for a facility include reasonable assurance that funds will
be available to decommission the facility. The FANR Board of Management is preparing its
recommendations to the Cabinet with respect to the establishment of the DTF and to
consider the necessary implementing regulations. A discussion paper regarding "The
Decommissioning Trust Fund" has been drafted by FANR to canvass the views of
stakeholders on a number of issues relevant to the establishment and implementation of
these regulations.
F.7
The Government of Abu Dhabi, through ENEC, currently funds the costs of
constructing the Barakah Nuclear Power Project and associated activities such as capacity
building and planning. ENEC may enter into a joint venture and lending arrangements for
the construction and development of the Barakah nuclear power project and has developed
a detailed proposal for the same working with Government of Abu Dhabi stakeholders,
KEPCO and a consortium of international lenders, including export credit agencies. In the
absence of any such arrangements, the Government of Abu Dhabi will continue to fund
ENEC's activities during the construction and development of the project.
F.8
ENEC is currently working with Government of Abu Dhabi stakeholders to structure a
power purchase agreement with the Abu Dhabi Water and Electricity Company (ADWEA) for the purchase of electricity produced by the Barakah NPP that will ensure revenue is available to the licensed operator to safely operate and maintain the facility. These revenue arrangements currently contemplate that the operator will recover costs incurred to meet
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its decommissioning obligations under applicable laws, including recovery of any fees that
are required to be paid into a decommissioning fund under applicable regulations, and for
meeting all fuel management and storage requirements.
F.9
The UAE has adopted the following two strategic goals associated with National
Regulatory Capacity Building (NRCB):
1. Support the national capacity building approach through effective coordination with
other UAE Government entities and stakeholders, in order to develop human resources in the nuclear sector.
2. Establish and maintain a National Regulatory Capacity Building (NRCB) Program
aimed at developing and sustaining an international-standard UAE national nuclear workforce.
The UAE human resources policy will be guided by the IAEA Document NG-G-3.1,
"Milestones in the Development of National Infrastructure for Nuclear Power", and its
recommendation that the relevant expertise required for each phase of the nuclear project
be established ahead of time. Initiation of the NRCB Program at FANR will, therefore, be a
priority and FANR will seek to achieve substantial progress in developing national regulatory
human resources in advance of facility construction and operation. Specific implementation
strategies have been developed to realize these goals, including ensuring the continuous
development of the overall human resource, including a special mechanism to fund ongoing
human resource development programs.
F.11
The NRCB effort is being implemented by FANR, ENEC and Khalifa University. These
three entities are working together across education, training, and recruitment lines to
ensure that the nuclear program's human resource needs are met at every stage of its
development. In addition, ENEC has partnered with the Institute of Applied Technology to
develop Emiratis at the technologist level to support the operation and maintenance of its
nuclear power plants.
F.12
FANR has developed the Emiratization approach for Capacity Building in
collaboration with the other UAE entities, and at the same time has created a program to
develop UAE Nationals internally. By using IAEA standards and guidance, primarily IAEA-
TECDOC-1254, "Training the staff of the regulatory body for nuclear facilities: A competency
framework" to determine a systematic approach to tasks needed for development, an initial
program for education and training is being implemented. Already results are evident, with
a number of UAE Nationals entering the nuclear workforce.
F.13
Finances have been provided as needed to develop staff and create the necessary
opportunities for international studies. Through international agreements with several
countries and their regulatory bodies, many opportunities exist and have been utilized for
UAE Nationals to perform job shadowing. See section E.38- E.43 for more information.
F.14
ENEC has developed a Human Resources Development (HRD) Strategy to identify the
capabilities needed to support the UAE nuclear energy program, assess the ability of the current market to provide those capabilities, and develop the required skills and abilities
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within the UAE in order to have a skilled local workforce available for the start of operations
in 2017. Aligned with the Emiratization goals of the UAE, the HRD Strategy intends to build
the human capacity of people in the UAE to support the nuclear industry, contributing to
the work of ENEC itself, the prime contractor, and the many businesses in the UAE that will
provide services to the overall program.
F.15
The strategy includes building a talent pool throughout the Emirates, starting the
educational process in grade school, and working to encompass academic, technical and vocational programs throughout the UAE and abroad. ENEC's current strategies are:
1. Leverage UAE Educational System and Build New Infrastructure 2. Develop Partnership Opportunities 3. Leverage Business and Industry 4. Broad Outreach: Grade School to Graduate Studies
Article 23: Quality Assurance
Each Contracting Party shall take the necessary steps to ensure that appropriate quality assurance programmes concerning the safety of spent fuel and radioactive waste management are established and implemented.
Quality Assurance
F.16
The UAE Nuclear Law Article (44) describes the requirements on the licensee to set
up a Management System and a Quality Assurance Program which shall be the subject of
approval and inspection by the Authority. FANR-REG-01 "Management Systems for Nuclear
Facilities" requires the licensee to establish, implement, assess and continually improve a
Management System that is aligned with the goals of the organisation and contributes to its
achievement (Article (3).
F.17
From the beginning of 2009, ENEC has developed and maintained a Quality
Management System (QMS), in compliance with UAE Law and Regulations covering the current phase of development for the Barakah NPP, as well as the commissioning phase. The Quality Management System includes a Quality Assurance Program which is in compliance with ASME NQA-1-1994 /1995 Addendum and applicable international IAEA and ISO standards on Quality Assurance for Nuclear Facility Applications. The current QMS scope covers Siting, Design, Procurement, Engineering, Construction, and Commissioning. The QA Manual covers all four Barakah NPP units, and was approved by the regulatory authority FANR as part of the ENEC construction license for Units 1 & 2. The ENEC QA Manual (EQAM) is now at Rev.04, and has incorporated a number of additional controls to prevent the entry of counterfeit, fraudulent and suspect items (CFSI) into the Barakah NPP supply chain. These are based on best industry practices and input received from regulatory bodies. As part of its QMS, ENEC has implemented a quality surveillance and auditing program that oversees the QA controls and measures for the Barakah NPP supply chain and construction site. ENEC conducts about 30-40 audits on its prime contractor KEPCO and its sub-contractors each year to verify program implementation and effectiveness. FANR also
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conducts a series of inspections of ENEC, KEPCO and contractors. The results of audits and
inspections are trended and continuous quality improvements are made as required.
F.18
Extensive reviews have been performed for the Barakah NPP to strengthen CFSI
controls as a result of recent CFSI findings for plants in the Republic of Korea. ENEC has
revised its QA program to strengthen CFSI controls including additional reviews of
certificates of compliance, enhanced audit practices, training of management and staff, and
the use of handheld devices that check the elemental composition of components. The
prime contractor QA program has also been enhanced to improve CFSI controls.
ENEC has developed an overall strategy and action plan to actively monitor CFSI issues
across the supply chain, which includes actions such as independent reviews of the prime
contractor CFSI programs and controls. ENEC also maintains close contact with industry
bodies, such as the Electric Power Research Institute (EPRI), Nuclear Energy Institute (NEI),
Department of Energy (DOE), Nuclear Procurement Issues Committee (NUPIC), and the
United States Nuclear Regulatory Commission (USNRC), and will continue to enhance its
CFSI measures as required.
F.19
ENEC shall ensure that the predisposal radioactive waste management facilities are
in compliance with FANR Regulations. ENEC, as the Licensee, will ensure that its prime
contractor, Korea Electric Power Company (KEPCO), which is responsible for the design,
construction, commission, and initial operation of the nuclear plants, performs a Safety
Assessment and develops a Safety Case for each identified waste stream.
Article 24: Operational radiation protection
1. Each Contracting Party shall take the appropriate steps to ensure that during the operating
lifetime of a spent fuel or radioactive waste management facility: (i) the radiation exposure of the workers and the public caused by the facility shall be kept
as low as reasonably achievable, economic and social factors being taken into account
(ii) no individual shall be exposed, in normal situations, to radiation doses which exceed
national prescriptions for dose limitation which have due regard to internationally endorsed standards on radiation protection and
(iii) measures are taken to prevent unplanned and uncontrolled releases of radioactive
materials into the environment
2. Each Contracting Party shall take appropriate steps to ensure that discharges shall be limited:
(i) to keep exposure to radiation as low as reasonably achievable, economic and social
factors being taken into account and
(ii) so that no individual shall be exposed, in normal situations, to radiation doses which
exceed national prescriptions for dose limitation which have due regard to internationally endorsed standards on radiation protection
3. Each Contracting Party shall take appropriate steps to ensure that during the operating
lifetime of a regulated nuclear facility, in the event that an unplanned or uncontrolled release of radioactive materials into the environment occurs, appropriate corrective measures are implemented to control the release and mitigate its effects.
At this stage, there are no spent fuel or radioactive waste management facilities in
the UAE. Any future facilities will be subject to FANR licensing under the provisions of the
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UAE Nuclear Law. This gives FANR the authority to regulate radiation protection in the
overall ‘Nuclear Sector' of the UAE, which includes nuclear facilities and industrial and
medical application of radioactive materials. See sections F.22 and F.23.
F.21
In order to ensure the utmost safety for both the Barakah NPP workforce on site and
the general public, the following laws and regulations set out below in Sections F.22 and
F.23 will be applied to the Barakah NPP radwaste and spent fuel management facilities. The
details are outlined in the plant Preliminary Safety Analysis Report, and will be further
discussed in the plant Final Safety Analysis Report.
F.22
UAE Nuclear Law Article (43) covers radiation safety and radiation protection. This
Article provides the basis for safety requirements in matters affecting radiation protection
and states:
"The Licensee shall ensure that Occupational Exposures and Public Exposures to Ionizing
Radiation and any releases of Radioactive Material to the environment caused by the
conduct of Regulated Activities are kept below the prescribed limits during all operational
states and Activities, and shall undertake to achieve Doses as low as reasonable achievable.
The licensee shall keep records of measured and estimated Doses and release data and
report them to the Authority as specified in the applicable regulations."
F.23
FANR has developed the following regulations and key provisions dealing directly
with radiation protection in nuclear facilities:
FANR-REG-04, "Regulation for Radiation Dose Limits and Optimisation of Radiation
Protection for Nuclear Facilities" covers:
Dose Limits for Occupational Exposure ,
Dose Limits for Members of the Public,
Optimisation of Protection for Workers , and
Optimisation of Protection for the Public.
This regulation adopts the internationally accepted dose limits for occupationally exposed workers during normal operation of a nuclear facility and for the general public.
FANR-REG-11, "Regulation for Radiation Protection and Predisposal Radioactive
Waste Management in Nuclear Facilities," covers:
Radiation Protection Programme,
Predisposal Management of Radioactive Waste,
Clearance Levels and Discharges of Radioactive Material,
Environmental Monitoring Programme, and
FANR-REG-06 "Regulation for an Application for a Licence to Construct a Nuclear
Facility" requires an applicant for a construction licence to describe in its application
preliminary information on the radiation protection programme including the design
features of the facility, and preliminary information on the programme for pre-
disposal management of radioactive waste.
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FANR-REG-13, "Transportation of Radioactive Material," has adopted IAEA
document TS-R-1 (2009 Edition), "Regulations for the Safe Transport of Radioactive Material," in its entirety. FANR are planning to update this version with the new "Regulations for the Safe Transport of Radioactive Material", 2012 Edition, SSR-6.
FANR-REG-14 "Regulation for an Application for a Licence to Operate a Nuclear
Facility" requires an applicant for an operating licence to describe in its application
preliminary information on the radiation protection programme including a
description of all onsite Radiation Sources, the application of the ALARA principle for
the optimisation of protection and design features for Radiation Protection of
personnel and the Nuclear Facility. In addition, it requires information on the
programme for pre-disposal management of Radioactive Waste including
arrangements for identification and control of Radioactive Waste streams, proposals
for authorised discharges of Radioactive Waste, and arrangements for pre-
treatment, treatment, conditioning and Storage of residual Radioactive Waste
pending disposal.
FANR-REG-16 "Regulation on Operational Safety including Commissioning"
requires the licensee of a nuclear facility to establish and implement a radiation protection programme and a programme for management of radioactive waste in accordance with the authority's requirements.
Regulatory requirements have been established to ensure that radioactive
discharges shall be limited consistent with international norms and standards. This is
included in Sections C5, G.16 and H.24 of this report.
F.25
The UAE government is currently working on developing policy regarding the long
term management and disposal of spent nuclear fuel and radioactive waste, and identifying
the entity that will be charged with implementing such policy as provided for in Article 41 of
the UAE Nuclear Law.
F.26
According to the UAE Nuclear Law Article 67, FANR's Board of Management formally
established the Radiation Protection Committee (RPC) as an advisory and consultative committee to FANR on 20 July 2011 in accordance with Article 67 of the Federal Law by Decree No 6 of 2009 Concerning the Peaceful Uses of Nuclear Energy. The RPC is charged with advising FANR on radiation protection. It was established to work with competent authorities; to develop radiation protection guidance as part of emergency response plans; to develop training programmes as appropriate; and to promote awareness and to improve the radiation protection infrastructure. The RPC held three meetings in 2013. During these meetings, the RPC considered a number of issues including:
A FANR and Health Authority Abu Dhabi (HAAD) joint inspection Storage of Orphan sources Status of the FANR Secondary Standard Dosimetry Laboratory (SSDL) Progress of Radiological Emergency Planning
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Radiation Detectors at the UAE Borders and Ports Update on FANR Regulatory Guide, and Criteria for Individual Monitoring Services recognition.
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Article 25: Emergency Preparedness
1. Each Contracting Party shall ensure that before and during operation of a spent fuel or
radioactive waste management facility there are appropriate on-site and, if necessary, off-site emergency plans. Such emergency plans should be tested at an appropriate frequency.
2. Each Contracting Party shall take the appropriate steps for the preparation and testing of
emergency plans for its territory insofar as it is likely to be affected in the event of a radiological emergency at a spent fuel or radioactive waste management facility in the vicinity of its territory.
F.27
Chapter 9 of the UAE Nuclear Law sets out a structure for emergency preparedness.
The relevant Articles include:
Article (49), which requires measures for Emergency Preparedness and Emergency
Response for protection of the population, property and environment (off-site Emergency plan) and for each Nuclear Facility and any facility that contains sources of ionizing radiation (on-site Emergency Plan)
Article (50), which requires preparation, maintenance and coordination of the off-
site Emergency Plan by the competent authorities and Licensees in order to provide protection of the public
Article (51), which stipulates that the material, technical, and human resources for
the preparation, maintenance, and implementation of the off-site Emergency Plan shall be financed by the State's national budget
Article (52), which requires that a licensee provide its Emergency Plan to FANR for
approval and other competent authorities of the State before the Commissioning of a Nuclear Facility and that the Emergency Plan be tested before Nuclear Facility Commissioning and during the course of Operation
Article (53), which requires that the Licensee familiarize its employees with the
Emergency Plans and conduct related training
Article (54), which requires, in case of an accident, Licensees to:
• notify FANR immediately; • warn the population and municipalities within the Emergency Zones and
other competent authorities immediately;
• take Emergency Action to mitigate and remedy the consequences of the
• control and regulate the exposure of the individuals engaged in Accident
mitigation and control;
• ensure continuous monitoring of radioactive releases into environment; and • perform any other obligations as may be established in the Emergency Plans,
the Federal Law by Decree No 6 of 2009, or the applicable regulations
Article (55), which requires that the terms and procedures for preparation of
Emergency Plans, the responsibilities and duties for implementation, the measures for mitigation and remediation of the consequences, and the arrangements for warning of the public be established by regulation.
In addition, Article (7) requires that FANR cooperate with and advise relevant
Government entities concerned with emergency preparedness and response.
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FANR-REG-12, "Regulation for Emergency Preparedness for Nuclear Facilities," covers
FANR requirements for applicant or licensee preparation and planning for and response to
emergencies at nuclear facilities. The purpose of the regulation is to ensure that the
applicant has an organisation that is capable of coping with emergencies and mitigating
their consequences, and that the applicant or licensee can perform assessment actions and
implement notification procedures. It also requires the applicant or licensee to demonstrate
that it has adequate emergency facilities and equipment, provides appropriate training,
maintains emergency preparedness, and is capable of recovery after an emergency. The
requirements for training arrangements and procedures for exercising emergency plans are
also included. FANR-REG-12 does not apply to the plans and activities of the off-site
coordinating agencies or response organisations.
F.29
FANR-REG-15 provides the requirements for the off-site emergency plan and was
drafted in consultation with NCEMA. This draft regulation defines: a) terms and procedures
for preparation of Off-site Emergency Plans; b) responsibilities and duties for
implementation; c) measures for mitigation and remediation of consequences; d)
arrangements for warning of the public; and e) measures for testing Emergency
Preparedness.
F.30
FANR regulations require comprehensive emergency plans be prepared and
periodically exercised to assure actions are taken to notify and protect citizens in the vicinity
of a nuclear facility during an emergency. For radioactive waste management and spent fuel
management at a nuclear power plant, the emergency preparedness program is modified by
license condition upon the facility's entry into the decommissioning phase. The revised
provisions for emergency preparedness and response will be modified commensurate with
the hazard of the materials remaining within the former controlled areas.
F.31
The structure and content of the Barakah NPP emergency preparedness program is
being developed consistent with the 16 planning standards outlined in USNRC NUREG-0654,
"Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants". ENEC is also working closely with off-site
agencies to facilitate their understanding of response to a radiological emergency and assist
with the off-site plan as needed. Both the on-site and off-site plans are planned for
submittal to FANR for review in late 2014. The first exercise of both on-site and off-site
plans is tentatively scheduled prior to fuel receipt at the Barakah NPP. A drill and exercise
plan is being developed and emergency preparedness familiarization training will be
provided to all plant employees.
F.32
The main elements of the national plan include the On-Site Emergency Plan
developed and implemented by the licensee, ENEC, and the Off-Site Emergency Plan developed under the leadership of NCEMA in coordination with other concerned entities. Planning for the national emergencies is coordinated under the "General Framework for Emergency Response" prepared by NCEMA in February, 2013. Notification and activation of emergency response occurs through the NCEMA National Operation Centre (NOC).
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ENEC is developing and implementing a standard emergency classification scheme
based on system and effluent parameters on which Federal and local response organizations
may rely for determining initial off-site response measures. The Emergency Plan provides for
four classes of emergencies: (1) General Emergency, (2) Site Area Emergency, (3) Alert and
(4) Unusual event.
F.34
The Emergency Plan will include predefined Emergency Action Levels (EALs) based
on the abnormal conditions for the nuclear facility, security related concerns, releases of
radioactive material, environmental measurements and other observable indicators. The
Emergency Plan will also include EALs for all abnormal conditions that correspond to each of
these classes of emergency. The emergency plan developed by ENEC will be implemented
by emergency procedures in the form of documents and instructions that will detail the
implementation actions and methods required to achieve the objectives of the
requirements in the FANR-REG-12.
F.35
The UAE is currently developing the Emergency Response plans including plans for
training and exercises. Completed activities consist of observation and discussion of
emergency response with other nuclear facility operators and regulators.
F.36
ENEC, NCEMA and FANR observed an emergency preparedness exercise at KEPCO's
Ulchin Nuclear Power Plant. They also received a briefing on Exelon's emergency
preparedness program and observed an emergency preparedness exercise at its Quad Cities
nuclear power plant. In addition, ENEC met with representatives of WANO, Tokyo Electric
Power Company, and Kansai Electric Power Company to discuss the Japanese approach to
radiological emergency preparedness and the lessons learned from the 2011 accident at the
Fukushima-Daiichi Nuclear Power Plant.
F.37
FANR is currently addressing the 2011 IRRS mission's recommendations and
suggestions regarding the national emergency preparedness and response. In the context of
emergency response, the UAE is also committed to an IAEA Emergency Preparedness
Review (EPREV) peer review mission planned to take place in 2015. See section K.8.
F.38
For radioactive waste treatment facilities that are not affiliated with nuclear
facilities, FANR-REG-24 Article (16) applies. The licensee is required to prepare and maintain
an Emergency Plan for protection of people, commensurate with the nature and magnitude
of the risk involved. The Emergency plan shall be subject to the approval of the Authority.
Article 26: Decommissioning
Each Contracting Party shall take the appropriate steps to ensure the safety of decommissioning of a nuclear facility. Such steps shall ensure that:
(i) qualified staff and adequate financial resources are available (ii) the provisions of Article 24 with respect to operational radiation protection, discharges and
unplanned and uncontrolled releases are applied
(iii) the provisions of Article 25 with respect to emergency preparedness are applied and (iv) records of information important to decommissioning are kept
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UAE Nuclear Law Article 42 states that "A juridical Person that is licensed to operate
a Nuclear Facility that generates or will generate Radioactive Waste shall pay fee into a trust
fund called "Decommissioning Trust Fund" established by a decision of the Cabinet according
to the Board's recommendation." The Article also describes what the fee shall cover.
F.40
FANR has prepared FANR-REG-21 "Decommissioning of Facilities" addressing
decommissioning activities including the decommissioning license termination criteria; and is planning to prepare FANR-REG-22, "Decommissioning Trust Fund." Regulation 21 and 22 will cover the requirements in Article 26 in the Joint Convention:
Ensuring that adequate financial resources are available during decommissioning is
addressed in F6. FANR-REG-21, Article (5) includes the responsibilities of the licensee during the decommissioning phase of the facility. One of these responsibilities is ensuring that properly trained, qualified and competent staff are available for the decommissioning project;
the provisions of JC Article 24 with respect to operational radiation protection,
discharges and unplanned and uncontrolled releases are applied during decommissioning as addressed in FANR-REG-21 Article (3) which requires that Radiation protection of persons who are exposed as a result of decommissioning actions shall be optimized with due regard to the relevant dose constraints.
FANR-REG-21, Article (5) requires that the licensee shall be responsible for all
aspects of safety, radiation protection and environmental protection during decommissioning.
the provisions of JC Article 25 with respect to emergency preparedness applied
during decommissioning are addressed in Section F.30
the maintenance of records important to decommissioning are addressed in FANR-
REG-21, Article 17
FANR-REG-14, "Regulation for an Application for a Licence to Operate a Nuclear
Facility", requires information on decommissioning and end-of-life aspects to be included in the operating license application. This is being developed and will be submitted with the Barakah operating license application.
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Section G. Safety of Spent Fuel Management
Article 4: General Safety Requirements
Each Contracting Party shall take the appropriate steps to ensure that at all stages of spent fuel management; individuals, society and the environment are adequately protected against radiological hazards. In so doing, each Contracting Party shall take the appropriate steps to:
(i) ensure that criticality and removal of residual heat generated during spent fuel
management are adequately addressed
(ii) ensure that the generation of radioactive waste associated with spent fuel management is
kept to the minimum practicable, consistent with the type of fuel cycle policy adopted
(iii) take into account interdependencies among the different steps in spent fuel management (iv) provide for effective protection of individuals, society and the environment, by applying at
the national level suitable protective methods as approved by the regulatory body, in the framework of its national legislation which has due regard to internationally endorsed criteria and standards
(v) take into account the biological, chemical and other hazards that may be associated with
spent fuel management
(vi) strive to avoid actions that impose reasonably predictable impacts on future generations
greater than those permitted for the current generation
(vii) aim to avoid imposing undue burdens on future generations
Criticality and Removal of Residual Heat
G.1
FANR-REG-03 Article (87) provides requirements for spent fuel handling and for
spent fuel storage in water pools.
Minimum Generation of Radioactive Waste
G.2
FANR-REG-11 Article (15.1) and FANR-REG-24 Article (30.2) require that the
generation of radioactive waste including waste associated with spent fuel management, be
kept to the minimum practicable.
Interdependencies
G.3
The UAE policy on long-term management of spent fuel will take into account
interdependencies among the different steps in spent fuel management.
Protection of Individuals
G.4
FANR-REG-11, Articles (3) through (13) requires a radiation protection programme,
that commensurate with the radiological hazards, to be put in place to ensure that doses to workers during normal operations are controlled and that the requirements for the limitation radiation doses of FANR-REG-04 are met. In addition FANR-REG-11 Article 23 states that; "1. The Licensee shall ensure that the Safety Case for gases and effluents shall describe:
a) the characteristics and activity of the material to be discharged, and the potential
points and methods of discharge;
b) all significant exposure pathways by which discharged radionuclides can deliver
Public Exposure;
c) the total amount of various radionuclides expected to be discharged per year; and d) the Doses to the Representative Person due to the planned discharges."
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2. The Licensee shall ensure that Doses arising from discharges meet the requirements of
FANR-REG-04, "Dose Limits and Optimisation for Nuclear Facilities".
Non Radiological Hazards
G.5
The UAE policy on long-term management of spent fuel will take into account
biological, chemical and other hazards that may be associated with spent fuel management.
Future Generation
G.6
While steps to "strive to avoid actions that impose reasonably predictable impacts on
future generations greater than those permitted for the current generation" is not explicitly
covered in FANR regulations, this IAEA Safety Fundamental (SF-1) principle No. 7 will be
applied by FANR. See section H.14.
G.7
While steps to "aim to avoid imposing undue burdens on future generations" are not
explicitly covered in FANR regulations, this IAEA Safety Fundamental (SF-1) Principle No. 7
will be applied by FANR. See section H.15.
G.8
ENEC has taken the following measures for the management of spent fuel:
• The design of Barakah NPP has sufficient capacity in the spent fuel storage
pool for 20 years of operation for each plant.
• ENEC has completed a dry storage feasibility study to ensure sufficient
allocation of space in the Barakah site layout plan for the construction of a dry storage facility if needed in the future. The study also evaluated the existing and planned site infrastructure to ensure spent fuel dry storage requirements are implemented early in the nuclear program development.
Article 5: Existing facilities
Each Contracting Party shall take the appropriate steps to review the safety of any spent fuel management facility existing at the time the Convention enters into force for that Contracting Party and to ensure that, if necessary, all reasonably practicable improvements are made to upgrade the safety of such a facility.
Currently, there are no spent fuel management facilities existing in the UAE, and the
UAE does not have an inventory of spent fuel to report. The UAE has no spent fuel
management past practices to report.
Article 6: Siting of proposed facilities
1. Each Contracting Party shall take the appropriate steps to ensure that procedures are
established and implemented for a proposed spent fuel management facility:
(i) to evaluate all relevant site-related factors likely to affect the safety of such a facility during
its operating lifetime
(ii) to evaluate the likely safety impact of such a facility on individuals, society and the
(iii) to make information on the safety of such a facility available to members of the public
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(iv) to consult Contracting Parties in the vicinity of such a facility, insofar as they are likely to be
affected by that facility, and provide them, upon their request, with general data relating to the facility to enable them to evaluate the likely safety impact of the facility upon their territory
2. In so doing, each Contracting Party shall take the appropriate steps to ensure that such
facilities shall not have unacceptable effects on other Contracting Parties by being sited in accordance with the general safety requirements of Article 4.
G.10 In accordance with Article (28)(1) of the UAE Nuclear Law, an applicant for a licence
to construct or operate a spent fuel management facility will be required to submit a
detailed evidence of safety that will be reviewed and assessed by FANR. Consistent with the
approach described in FANR-REG-11, any proposal for a spent fuel management facility will
need to establish a Safety Case (see definition in section G.15.) The characteristics of the
siting of the facility will be a part of the Safety Case. It is expected that the relevant
requirements of FANR-REG-02, "Siting of Nuclear Facilities" would apply.
G.11 Spent fuel pool storage is currently considered in the design of Barakah NPP and
FANR requirements have been addressed in the Preliminary Safety Analysis Report (PSAR).
ENEC also envisions that capability may be required for the dry storage of spent fuel. ENEC
will comply with FANR requirements in the siting and design of the dry fuel storage facility.
Article 7: Design and construction of facilities
Each Contracting Party shall take the appropriate steps to ensure that:
(i) the design and construction of a spent fuel management facility provide for suitable
measures to limit possible radiological impacts on individuals, society and the environment, including those from discharges or uncontrolled releases;
(ii) at the design stage, conceptual plans and, as necessary, technical provisions for the
decommissioning of a spent fuel management facility are taken into account;
(iii) the technologies incorporated in the design and construction of a spent fuel management
facility are supported by experience, testing or analysis.
G.12 In accordance with Article (28)(1) of the UAE Nuclear Law, an applicant for a licence
to construct or operate a spent fuel management facility would be required to submit a
detailed evidence of safety that would be reviewed and assessed by FANR. Consistent with
the approach described in FANR-REG-11, any proposal for a spent fuel management facility
would need to establish a Safety Case. The approach to the design and construction of the
facility would be a part of the safety case. It would be expected that the relevant
requirements of FANR-REG-03 "Design of Nuclear Power Plants" and FANR-REG-14
"Construction of a Nuclear Facility" would apply.
G.13 FANR-REG- 3 "Regulation for the Design of Nuclear Power Plants" Article 82 states:
"Adequate systems shall be provided to treat radioactive liquid and gaseous effluents in
order to keep Doses arising from Discharge of Radioactive Material within the Dose limits
established by REG-04, Regulation for Radiation Dose Limits and Optimisation of Radiation
Protection for Nuclear Facilities and subject to optimisation of protection as defined in that
Regulation".
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To ensure that spent fuel and radioactive waste management facilities are designed and
constructed to limit possible radiological impacts and discharges throughout their life cycle,
reviews of the proposed design and operation of the facilities are conducted against well-
established design and construction criteria in the regulations. Subsequent monitoring and
inspection during the construction process provide confidence that the facilities will operate
safely.
G.14 ENEC has ensured sufficient capacity in the spent fuel storage pool for 20 years of
operation for each unit at Barakah NPP. ENEC also plans to reserve sufficient space in the
Barakah site layout plan for the construction of a dry storage facility if needed in the future.
Article 8: Assessment of safety of facilities
Each Contracting Party shall take the appropriate steps to ensure that:
(i) before construction of a spent fuel management facility, a systematic safety assessment and
an environmental assessment appropriate to the hazard presented by the facility and covering its operating lifetime shall be carried out
(ii) before the operation of a spent fuel management facility, updated and detailed versions of
the safety assessment and of the environmental assessment shall be prepared when deemed necessary to complement the assessments referred to in paragraph (i)
G.15 In accordance with Article (28)(1) of the UAE Nuclear Law, an applicant for a licence
to construct or operate a spent fuel management facility will be required to submit a
detailed evidence of safety that would be reviewed and assessed by FANR. Environmental
assessment will be carried out by the relevant competent authority (e.g. the Environment
Agency of Abu Dhabi). Consistent with the approach described in FANR-REG-11, any
proposal for a spent fuel management facility will need to establish a Safety Case. This is
defined as: "A collection of arguments and evidence in support of the Safety of a Facility or
Activity including the findings of a Safety assessment and a statement of confidence in these
findings."
G.16 Consistent with the approach taken in FANR regulations of Nuclear Facilities to date,
FANR reviews and assesses a preliminary safety case at the stage of seeking a construction
licence followed by a final safety case at the stage of the operating licence. FANR-REG-11,
Article (23) states:
1. "The Licensee shall ensure that the Safety Case for gases and effluents shall describe:
a) the characteristics and activity of the material to be discharged, and the
potential points and methods of discharge;
b) all significant exposure pathways by which discharged radionuclides can
deliver Public Exposure;
c) the total amount of various radionuclides expected to be discharged per
d) the Doses to the Representative Person due to the planned discharges.
2. The Licensee shall ensure that Doses arising from discharges meet the requirements
of FANR-REG 04 Dose Limits and Optimisation for Nuclear Facilities.
3. The Licensee shall, review and adjust the discharge control measures taking into
a) Operating experience
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b) Any changes in exposure pathways and the characteristics of the critical
group that could affect the assessment of Doses due to the discharges.
4. The Licensee shall record the details of all gaseous and liquid discharges, including
estimates of any unmonitored discharges, in the source monitoring programme. "
G.17 Consistent with the approach taken in FANR regulation of Nuclear Facilities to date,
ENEC submitted an application to FANR on 27 December 2010 for the construction of the
first two units of the nuclear facility at the Barakah site (Barakah Units 1 and 2). The
application requested authorisation to conduct all regulated activities required to construct
the plant, including management of spent fuel and radioactive waste. On 28 February 2013,
ENEC submitted to FANR a further application for authorisation to construct the third and
fourth APR-1400 units at the Barakah site. This application is currently under review by
FANR.
In addition, ENEC prepared a Non-Nuclear-Environmental Impact Assessment (NN-EIA) and a
Nuclear-Environmental Impact Assessment (N-EIA) for BNPP Units 1, 2, 3 and 4 that was
submitted to the Environment Agency of Abu Dhabi (EAD). Based on the EAD review of the
NN-EIA and the N-EIA, a "No Objection Certificate" was granted for the non-nuclear and
nuclear construction activities for Barakah Units 1 and 2 according to the technical details
and plans included in the project environmental impact assessment report (number S439)
and the project environmental management plan (number S433). EAD recently issued "No
Objection Certificate" for nuclear construction activities for Barakah units 1, 2, 3, and 4
according to approval EIA report (S943) and its Ref. (EMS/14/ESRF816).
G.18 ENEC has ensured sufficient capacity in the spent fuel storage pool for 20 years of
operation for each unit at Barakah NPP. ENEC also plans to reserve sufficient space in the
Barakah site layout plan for the construction of dry storage facility if needed in the future.
Article 9: Operation of facilities
Each Contracting Party shall take the appropriate steps to ensure that:
(i) the licence to operate a spent fuel management facility is based upon appropriate
assessments as specified in Article 8 and is conditional on the completion of a commissioning programme demonstrating that the facility, as constructed, is consistent with design and safety requirements
(ii) operational limits and conditions derived from tests, operational experience and the
assessments, as specified in Article 8, are defined and revised as necessary
(iii) operation, maintenance, monitoring, inspection and testing of a spent fuel management
facility are conducted in accordance with established procedures
(iv) engineering and technical support in all safety-related fields are available throughout the
operating lifetime of a spent fuel management facility
(v) incidents significant to safety are reported in a timely manner by the holder of the licence to
the regulatory body
(vi) programmes to collect and analyse relevant operating experience are established and that
the results are acted upon, where appropriate
(vii) decommissioning plans for a spent fuel management facility are prepared and updated, as
necessary, using information obtained during the operating lifetime of that facility, and are reviewed by the regulatory body
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G.19 All the above requirements are included in the FANR regulations dealing with
Nuclear Facilities (including spent fuel management facilities) and would be appropriately
applied to any proposed spent fuel management facility.
Article 10: Disposal of spent fuel
If, pursuant to its own legislative and regulatory framework, a Contracting Party has designated spent fuel for disposal, the disposal of such spent fuel shall be in accordance with the obligations of Chapter 3 relating to the disposal of radioactive waste.
G.20 Should the UAE designate spent fuel for disposal as part of its spent fuel and
radioactive waste management strategy, these provisions would apply.
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Section H. Safety of Radioactive Waste Management
Article 11: General Safety Requirements
Each Contracting Party shall take the appropriate steps to ensure that at all stages of radioactive waste management individuals, society and the environment are adequately protected against radiological and other hazards. In so doing, each Contracting Party shall take the appropriate steps to:
(i) ensure that criticality and removal of residual heat generated during radioactive waste
management are adequately addressed,
(ii) ensure that the generation of radioactive waste is kept to the minimum practicable (iii) take into account interdependencies among the different steps in radioactive waste
(iv) provide for effective protection of individuals, society and the environment, by applying at
the national level suitable protective methods as approved by the regulatory body, in the framework of its national legislation which has due regard to internationally endorsed criteria and standards
(v) take into account the biological, chemical and other hazards that may be associated with
radioactive waste management
(vi) strive to avoid actions that impose reasonably predictable impacts on future generations
greater than those permitted for the current generation
(vii) aim to avoid imposing undue burdens on future generations
FANR-REG-11 "Regulation for Radiation Protection and Predisposal Radioactive
Waste Management in Nuclear Facilities" contains a chapter about Predisposal
Management of Radioactive Waste. FANR-REG-24, "Basic Safety Standards for Facilities and
Activities involving Ionizing Radiation other than in Nuclear Facilities" contains paragraphs
on radioactive waste management. Both regulations are complemented by draft FANR-REG-
26 "Predisposal Management of Radioactive Waste" and Draft FANR-RG-018 "Predisposal
Radioactive Waste Management" which contains more requirements on pre-disposal
management of radioactive waste.
General Obligations of license holder
H.2
Article (14) of FANR-REG-11 requires the licensee to be responsible for the waste
until its delivery to the entity designated by the Cabinet of Ministers for the purpose of
disposal. It also requires the licensee to carry out a Safety Assessment and develop a Safety
Case for each identified waste stream including all phases of a radioactive waste
management facility's life span. The Licensee is required to implement measures to ensure
an integrated approach to safety and security
H.3
ENEC is responsible for the safe management and storage of Radioactive Waste
generated from Barakah NPP until its delivery to the WMO or operator of a waste management facility. This includes the following responsibilities:
The safety of predisposal radioactive waste management for Barakah NPP and its
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Carrying out safety assessments and developing a safety case for each identified
Ensuring that the siting, design, construction, commissioning, operation, shut down
and decommissioning of the Barakah NPP are carried out in compliance with FANR regulations.
Implementing measures to ensure an integrated approach to safety in the
predisposal management of Radioactive Waste.
Applying the management system established in accordance with FANR-REG-01 for
all steps and elements of the Predisposal Management of Radioactive Waste.
Waste minimization
H.4
Article (15) of FANR-REG-11 requires the Licensee to identify all radioactive waste
and keep radioactive waste to a minimum. It also states that the Licensee shall consider the
authorized discharge of effluent and the clearance of material from Regulatory control after
processing and/or storage, together with reuse and recycling of material in order to reduce
the amount of waste that needs further processing or storage.
H.5
Article (5) of FANR-RG-018 (draft) provides useful strategies for waste minimization.
This guidance provides considerations that should be given to the design of the facility and
to operational features for waste minimization.
H.6
ENEC has committed to complying with the USNRC Regulatory Guide 4.21,
"Minimization of Contamination and Radioactive Waste Generation: Life-Cycle Planning",
which provides additional information on minimization of waste throughout all stages of the
nuclear fuel cycle, including disposal. This guidance provides examples of measures, which
can be combined to support a contaminant management philosophy. This philosophy
includes prevention of unintended release, early detection of potential releases, and proper
cleanup when releases happen.
H.7
Barakah NPP has been designed, is being constructed and will be operated in a
manner that keeps radioactive waste volume to a minimum practicable with proven
technologies.
Furthermore, ENEC is committed to adopting appropriate processes for the responsible
discharge of effluents, in addition to the clearance of material from regulatory control.
These processes include the reuse, recycling and storage of material.
Interdependences among different steps
H.8
Article (14.4) of FANR-REG-11 states that the licensee shall take into account
interdependencies among all steps in the predisposal waste management of radioactive
waste, as well as the impact of the anticipated disposal option as this becomes known to be
able to consider the radioactive waste management in an integrated manner.
H.9
The steps adopted for predisposal waste management at Barakah NPP are widely
accepted amongst the nuclear industry worldwide. Because each step and technology has
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interdependencies with other steps, predisposal waste management will be executed in an
integrated manner to minimize the waste volume and radiation exposure to workers and
general public.
Protection of individuals, society and the environment
H.10 Article (24) of FANR-REG-11 describes the Licensee's obligations with regard to
establishing an environmental monitoring program to ensure that public exposure is
adequately assessed and is sufficient to demonstrate compliance with the regulations. The
article also describes minimum requirements on what the programme shall include.
H. 11 ENEC is establishing an environmental monitoring program to comply with
governmental regulations. As a part of this program, environmental samples are being
collected, analyzed and documented in advance of operations, in order to collect baseline
environmental data.
Non radiological hazards in waste management
H.12 Article (16) of FANR-REG-11 requires the Licensee to characterize waste in terms of
its physical, mechanical, chemical radiological and biological properties at various steps and
classify it appropriately, including from the perspective of its future disposal.
H.13 ENEC characterizes waste according to the regulatory requirements. According to
physical properties, waste will be classified into gaseous, liquid and solid wastes.
Based on these detailed classifications, appropriate technologies will be applied to treat
waste. Furthermore, there will be an effort to identify non-radioactive waste, which will be
separated from radioactive waste and disposed of accordingly, in order to minimize the
radioactive waste volume and to optimize doses to workers and the general public in
accordance with the governmental regulations.
Strive to avoid actions that impose impacts on future generations
H.14 While not explicitly covered in the Regulation, this IAEA Safety Fundamental (SF-1)
principle No. 7 is included in the UAE Nuclear Law Article (11.4.a) where the FANR Board is
authorized "to protect the individuals, society and the environment from radiation hazards,
both for the present and in the future".
Aim to avoid to impose undue burden on future generations
H.15 While not explicitly covered in the Regulation, this IAEA Safety Fundamental (SF-1)
principle No. 7 is included in the UAE Nuclear Law Article (11.4.a) where the FANR Board is
authorized "to protect the individuals, society and the environment from radiation hazards,
both for the present and in the future".
H.16 ENEC's overriding priority is ensuring the safety of the UAE community, its
employees and the environment. ENEC understands its obligation to future generations and
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strives to conduct its activities with long-term sustainability in mind, avoiding any undue
impacts. ENEC will process radioactive waste to the minimum waste volume achievable,
maintaining high quality waste form, which will reduce the burden on ultimate disposal and
ensure long term protection of the environment and the nation's future generations.
Article 12: Existing facilities and past practices
Each Contracting Party shall in due course take the appropriate steps to review:
(i) the safety of any radioactive waste management facility existing at the time the Convention
enters into force for that Contracting Party and to ensure that, if necessary, all reasonably practicable improvements are made to upgrade the safety of such a facility
(ii) the results of past practices in order to determine whether any intervention is needed for
reasons of radiation protection bearing in mind that the reduction in detriment resulting from the reduction in dose should be sufficient to justify the harm and the costs, including the social costs, of the intervention
H.17 Currently, there are no radioactive waste management facilities in the UAE.
Article 13: Siting of proposed facilities.
1. Each Contracting Party shall take the appropriate steps to ensure that procedures are
established and implemented for a proposed radioactive waste management facility:
(i) to evaluate all relevant site-related factors likely to affect the safety of such a facility
during its operating lifetime as well as that of a disposal facility after closure
(ii) to evaluate the likely safety impact of such a facility on individuals, society and the
environment, taking into account possible evolution of the site conditions of disposal facilities after closure
(iii) to make information on the safety of such a facility available to members of the public (iv) to consult Contracting Parties in the vicinity of such a facility, insofar as they are likely to
be affected by that facility, and provide them, upon their request, with general data relating to the facility to enable them to evaluate the likely safety impact of the facility upon their territory
2. In so doing, each Contracting Party shall take the appropriate steps to ensure that such
facilities shall not have unacceptable effects
H.18 In accordance with Article (28)(1) of the UAE Nuclear Law, an applicant for a licence
to construct or operate a radioactive waste management facility will be required to submit
detailed evidence of safety that will be reviewed and assessed by FANR. Consistent with the
approach described in FANR-REG-11, a Safety Case and supporting Safety Assessment for a
radioactive waste management facility would need to be reviewed and assessed by FANR.
The characteristics of the siting of the facility would be a part of the Safety Case. It is
expected that the relevant requirements of FANR-REG-02 "Siting of Nuclear Facilities" would
apply.
H.19 ENEC, as the owner and operator of Barakah NPP, will be responsible for the safe
operation and maintenance of the plant, including minimizing the generation of radioactive
waste and overseeing the safe storage of any waste within the site boundary.
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In order to optimize doses to plant workers and the general public, the international
standards and FANR regulations have been applied to the design, construction, and
operation of Barakah NPP radwaste and spent fuel management. The details are described
in the plant Preliminary Safety Analysis Report and will be further discussed in the plant
Final Safety Analysis Report.
Once plans for the UAE's radioactive waste management facilities are finalized, and the
WMO who will operate these facilities is in place, ENEC will cooperate with the appointed
WMO to ensure radiation safety for both workers and general public.
Article 14: Design and construction of facilities.
Each Contracting Party shall take the appropriate steps to ensure that:
(i) the design and construction of a radioactive waste management facility provide for suitable
measures to limit possible radiological impacts on individuals, society and the environment, including those from discharges or uncontrolled releases
(ii) at the design stage, conceptual plans and, as necessary, technical provisions for the
decommissioning of a radioactive waste management facility other than a disposal facility are taken into account
(iii) at the design stage, technical provisions for the closure of a disposal facility are prepared (iv) the technologies incorporated in the design and construction of a radioactive waste
management facility are supported by experience, testing or analysis
H.20 In accordance with Article (28)(1) of the UAE Nuclear Law, an applicant for a licence
to construct or operate a radioactive waste management facility will be required to submit
detailed evidence of safety that will be reviewed and assessed by FANR. Consistent with the
approach described in FANR-REG-11, any proposal for a radioactive waste management
facility would need to establish a Safety Case. The approach to the design and construction
of the facility would be a part of the Safety Case. It is expected that the relevant
requirements of FANR-REG-03 ‘Design of Nuclear Power Plants' and FANR-REG-14
‘Construction of a Nuclear Facility" would apply.
H.21 FANR-REG- 3 "Regulation for the Design of Nuclear Power Plants" Article 82 states:
"Adequate systems shall be provided to treat radioactive liquid and gaseous effluents in
order to keep Doses arising from Discharge of Radioactive Material within the Dose limits
established by REG-04, Regulation for Radiation Dose Limits and Optimisation of Radiation
Protection for Nuclear Facilities and subject to optimisation of protection as defined in that
Regulation".
To ensure that the spent fuel and radioactive waste management facilities are designed and
constructed to limit possible radiological impacts and discharges throughout their life cycle,
FANR will review the proposed design and operation of the facilities against well-established
design and construction criteria in the regulations. Subsequent monitoring and inspection
during the construction process, by FANR will provide confidence that the facilities will
operate safely.
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H 22 When plans for the UAE's radioactive waste management facilities are finalized, and
the WMO who will operate these facilities is in place, ENEC will cooperate with the
appointed WMO to ensure radiation safety for both workers and general public.
Article 15: Assessment of safety of facilities
Each Contracting Party shall take the appropriate steps to ensure that:
(i) before construction of a radioactive waste management facility, a systematic safety
assessment and an environmental assessment appropriate to the hazard presented by the facility and covering its operating lifetime shall be carried out
(ii) in addition, before construction of a disposal facility, a systematic safety assessment and an
environmental assessment for the period following closure shall be carried out and the results evaluated against the criteria established by the regulatory body
(iii) before the operation of a radioactive waste management facility, updated and detailed
versions of the safety assessment and of the environmental assessment shall be prepared when deemed necessary to complement the assessments referred to in paragraph (i)
H.23 In accordance with Article (28)(1) of the UAE Nuclear Law, an applicant for a licence
to construct or operate a spent fuel management facility would be required to submit
detailed evidence of safety that would be reviewed and assessed by FANR. Environmental
assessment would be carried out by the relevant competent authority (e.g. the Environment
Agency of Abu Dhabi see section G.17). Consistent with the approach described in FANR-
REG-11, a Safety Case and supporting Safety Assessment for a spent fuel management
facility would need to be reviewed and assessed by FANR. This is defined as: "A collection of
arguments and evidence in support of the Safety of a Facility or Activity including the
findings of a Safety assessment and a statement of confidence in these findings."
H.24 Consistent with the approach taken in its regulation of Nuclear Facilities to date,
FANR would expect a preliminary safety case at the stage of seeking a construction licence
followed by a final safety case at the stage of the operating licence. FANR-REG-11, Article
(23) states:
1. "The Licensee shall ensure that the Safety Case for gases and effluents shall describe:
a) the characteristics and activity of the material to be discharged, and the
potential points and methods of discharge;
b) all significant exposure pathways by which discharged radionuclides can
deliver Public Exposure;
c) the total amount of various radionuclides expected to be discharged per
d) the Doses to the Representative Person due to the planned discharges.
2. The Licensee shall ensure that Doses arising from discharges meet the requirements
of FANR REG 04 Dose Limits and Optimisation for Nuclear Facilities.
3. The Licensee shall, review and adjust the discharge control measures taking into
a) Operating experience b) Any changes in exposure pathways and the characteristics of the critical
group that could affect the assessment of Doses due to the discharges.
4. The Licensee shall record the details of all gaseous and liquid discharges, including
estimates of any unmonitored discharges, in the source monitoring programme. "
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H.25 When plans for the UAE's radioactive waste management facilities are finalized, and
the WMO who will operate these facilities is in place, ENEC will cooperate with the
appointed WMO to ensure radiation safety for both workers and general public.
Article 16: Operation of facilities
Each Contracting Party shall take the appropriate steps to ensure that:
the licence to operate a radioactive waste management facility is based upon appropriate assessments as specified in Article 15 and is conditional on the completion of a commissioning programme demonstrating that the facility, as constructed, is consistent with design and safety requirements
operational limits and conditions, derived from tests, operational experience and the assessments as specified in Article 15 are defined and revised as necessary
operation, maintenance, monitoring, inspection and testing of a radioactive waste management facility are conducted in accordance with established procedures. For a disposal facility the results thus obtained shall be used to verify and to review the validity of assumptions made and to update the assessments as specified in Article 15 for the period after closure
engineering and technical support in all safety-related fields are available throughout the operating lifetime of a radioactive waste management facility
procedures for characterization and segregation of radioactive waste are applied
incidents significant to safety are reported in a timely manner by the holder of the licence to the regulatory body;
(vii) programmes to collect and analyse relevant operating experience are established
and that the results are acted upon, where appropriate
(viii) decommissioning plans for a radioactive waste management facility other than a
disposal facility are prepared and updated, as necessary, using information obtained during the operating lifetime of that facility, and are reviewed by the regulatory body
plans for the closure of a disposal facility are prepared and updated, as necessary, using information obtained during the operating lifetime of that facility and are reviewed by the regulatory body
H.26 All the above requirements are included in the FANR regulations dealing with
Nuclear Facilities (including radioactive waste management facilities) and would be
appropriately applied to any proposed radioactive waste management facility.
H.27 The operation of the radioactive waste management facility at an operating nuclear
power plant will be addressed within the context of the safety case associated with the
operating facility.
H.28 When plans for the UAE's radioactive waste management facilities are finalized, and
the WMO who will operate these facilities is in place, ENEC will cooperate with the
appointed WMO to ensure radiation safety for both workers and general public.
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Article 17: Institutional measures after closure
Each Contracting Party shall take the appropriate steps to ensure that after closure of a disposal facility:
(i) records of the location, design and inventory of that facility required by the regulatory body
(ii) active or passive institutional controls such as monitoring or access restrictions are carried
out, if required and
(iii) if, during any period of active institutional control, an unplanned release of radioactive
materials into the environment is detected, intervention measures are implemented, if necessary
H.29 These obligations of the Joint Convention will be included in the FANR-REG-27
concerning radioactive waste disposal facilities now under development. This regulation is
based on IAEA Safety Standards Requirement No. SSR-5, "Disposal of Radioactive Waste"
where all the obligations are included.
H.30 The scope of draft FANR-REG-27 is described below.
1. This regulation applies to the disposal of radioactive waste of all types by means of
emplacement in designed disposal facilities, subject to the necessary limitations and controls being placed on the disposal of the waste and on the development, operation and closure of facilities. The classification of radioactive waste is discussed in FANR-REG-26 and FANR-RG-018.
2. This regulation will establish the safety requirements to provide assurance of the
radiation safety of the disposal of radioactive waste, in the operation of a disposal facility and especially after its closure. The fundamental safety objective is to protect people and the environment from harmful effects of ionizing radiation. This is achieved by setting requirements on the site selection and evaluation and design of a disposal facility, its construction, operation and closure, including organizational and regulatory requirements.
3. This regulation does not address the transport of waste to the site or environmental
impacts other than radiological consequences.
4. This regulation does not address the process of involving interested parties in
decision making processes for selecting sites for disposal facilities.
It addresses the following disposal options, corresponding to recognized classes of radioactive waste:
(a) Specific landfill disposal facility for the disposal of very low level radioactive waste
(VLLW) with low concentrations or quantities of radioactive content. Typical waste disposed of in a facility of this type may include soil and rubble arising from decommissioning activities.
(b) Near surface disposal facility for the disposal of low level radioactive waste (LLW).
(c) Intermediate level waste disposal facility for the disposal of intermediate level
radioactive waste (ILW)
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(d) Geological disposal facility for the disposal of high level radioactive waste (HLW),
including spent fuel if it is to be treated as waste.
(e) Borehole disposal facility for the disposal of only relatively small volumes of waste, in
particular disused sealed radioactive sources.
It addresses the safety requirements during three periods associated with the development, operation and closure of a disposal facility:
the pre-operational period
the operational period and
the post-closure period.
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Section I Transboundary Movement
Article 27: Transboundary Movement
1. Each Contracting Party involved in transboundary movement shall take the appropriate steps
to ensure that such movement is undertaken in a manner consistent with the provisions of this Convention and relevant binding international instruments. In so doing:
(i) a Contracting Party which is a State of origin shall take the appropriate steps to ensure
that transboundary movement is authorized and takes place only with the prior notification and consent of the State of destination
(ii) transboundary movement through States of transit shall be subject to those international
obligations which are relevant to the particular modes of transport utilized
(iii) a Contracting Party which is a State of destination shall consent to a transboundary
movement only if it has the administrative and technical capacity, as well as the regulatory structure, needed to manage the spent fuel or the radioactive waste in a manner consistent with this Convention
(iv) a Contracting Party which is a State of origin shall authorize a transboundary movement
only if it can satisfy itself in accordance with the consent of the State of destination that the requirements of subparagraph (iii) are met prior to transboundary movement
(v) a Contracting Party which is a State of origin shall take the appropriate steps to permit re-
entry into its territory, if a transboundary movement is not or cannot be completed in conformity with this Article , unless an alternative safe arrangement can be made
2. A Contracting Party shall not licence the shipment of its spent fuel or radioactive waste to a
destination south of latitude 60 degrees South for storage or disposal.
3. Nothing in this Convention prejudices or affects:
(i) the exercise, by ships and aircraft of all States, of maritime, river and air navigation rights
and freedoms, as provided for in international law
(ii) rights of a Contracting Party to which radioactive waste is exported for processing to
return, or provide for the return of, the radioactive waste and other products after treatment to the State of origin
(iii) the right of a Contracting Party to export its spent fuel for reprocessing (iv) rights of a Contracting Party to which spent fuel is exported for reprocessing to return, or
provide for the return of, radioactive waste and other products resulting from reprocessing operations to the State of origin
As a Contracting Party to the Joint Convention, the UAE adopts and supports the
objectives of Article (27) without exception. Import of spent fuel and nuclear waste into the UAE for the purpose of long term storage or disposal is prohibited under the UAE Nuclear Law, Article (41.3).
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Section J. Disused Sealed Sources
Article 28: Disused sealed sources
1. Each Contracting Party shall, in the framework of its national law, take the appropriate steps to
ensure that the possession, remanufacturing or disposal of disused sealed sources takes place in a safe manner.
2. A Contracting Party shall allow for reentry into its territory of disused sealed sources if, in the
framework of its national law, it has accepted that they be returned to a manufacturer qualified to receive and possess the disused sealed sources.
The ‘possession, use, manufacture or handling' and the ‘storage' and ‘disposal' of
Regulated Material are Regulated Activities under Article 25 of the UAE Nuclear Law. The
definition of Regulated Material clearly includes sealed radioactive sources (with activity
above the UAE exemption levels). Therefore, the ‘possession, remanufacturing or disposal'
of disused sources is subject to licensing by FANR with the associated need for safety to be
demonstrated.
J.2
In general, UAE users of sealed sources should have contractual arrangements to
return disused sealed sources to the manufacturer. The verification of these arrangements
is an important part of FANR's review and assessment and regulatory oversight of these
licensees. Article (18.8) of FANR-REG-24 requires that licensees ensure that arrangements
are made for the safe management and disposition of radioactive sources, including
financial provisions where appropriate, once they have become disused.
J.3
FANR also has power under Article (5.32) of the UAE Nuclear Law to develop a
strategy to ensure radiation protection from orphan sources. Such a strategy is under
development and will be reported on at the Fifth Review Meeting.
J.4
Part of the orphan source strategy was to find a central storage facility for the
sources. This is now accomplished and the sources will be moved to this facility. The
planned strategy for locating orphan sources will proceed.
J.5
At the 4th review meeting FANR reported 12 orphan sources. Four of these sources
were not orphan but disused and has now been exported for reuse. The UAE still has 8 orphan sources registered in the Orphan Source Register. Sources in use and disused sources are registered in the Regulatory Authority Information System (RAIS). See Annex A.2.
United Arab Emirates Second National Report
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Section K. General Efforts to Improve Safety
K.1
The discussion contained in this second UAE Joint Convention National Report of
actions taken by the UAE, as a Contracting Party, regarding the obligations under relevant
Articles of the Joint Convention confirms the continuous conscientious and systematic effort
by relevant bodies in the UAE to fully implement these provisions in developing the UAE
programme for the peaceful uses of nuclear energy. Even at this early stage in the
programme, the UAE government has recognized the need to put into place the necessary
legislative, regulatory, and organisational framework to ensure the safety, security and
environmental acceptability of its spent fuel management and radioactive waste
management. This National Report is the second Joint Convention report submitted by the
United Arab Emirates and, thus, reflects the fact that additional measures will be needed
over the coming months and years as the programme evolves and progresses. Relevant UAE
organisations are fully committed to meeting the obligations of this Joint Convention and
actively participating in the peer review process established under the Joint Convention. The
UAE has adopted a policy of transparency regarding its nuclear programme, including spent
fuel and radioactive waste, and will continue to make available a full range of information
on how it is meeting its responsibilities to ensure safety, security and safeguards in the
future. The UAE looks forward to receiving the questions and comments of other Joint
Convention Contracting Parties on this National Report and is committed to clarifying any
issues raised both in its responses to questions or comments and during the May 2015 Joint
Convention review meeting.
UAE's First report on compliance with the obligation of the Joint Convention
K.2
During the period before the meeting in May 2012, UAE received 41 questions to be
answered. The questions concerned several articles of the Joint Convention and were
mostly requests for clarifications and related to matters of the longer term strategy of the
UAE for storage and disposal of spent fuel and radioactive waste. All questions were
answered on the Joint Convention website and commented in a general sense at the
meeting.
Outcome from Last Joint Convention Review Meeting in 2012
K.3
During the discussion at the Joint Convention Review Meeting in 2012 it was
concluded that the UAE's first report demonstrated a strong commitment to the Joint
Convention which for UAE entered into force in October 2009, at the same time as the
Federal Authority for Nuclear Regulation (FANR) was established. It was also concluded that
the Policy Statement from 2008 (Policy of the United Arab Emirates on the Evaluation and
Potential Development of Peaceful Nuclear Energy) would be followed by a more developed
strategy later in 2012.
K.4
Highlights from the UAE's first report was "Policy of the UAE on the Evaluation & Potential Development of Peaceful
Nuclear Energy" issued in April 2008
Establishment of the Federal Law by Decree No 6 of 2009 ‘"Concerning the
Peaceful Uses of Nuclear Energy"
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Construction license application for the first two units of NPPs submitted in Dec.
Development of FANR regulations and guides: 11 regulations and 4 guides
approved and issued; 5 regulations in draft
Review of SF management responding to Fukushima accident : Based upon the
ENSREG/WENRA stress test specifications
Survey of licensees to verify radioactive waste inventory and presentation of the
first national inventory at the 4th review meeting
It was noted the UAE demonstrated good practices with regard to; Decision to meet obligations of JC and participate in its peer review process High-level policy statement and commitments to capacity building at an early
stage of nuclear programme
Establishment of an independent regulatory body and setting out the Framework
for Radioactive Waste Management in the UAE Nuclear Law in accordance with IAEA and international safety standards
Beneficial use of international peer reviews for transparency and mutual
learning: INIR Mission and IRRS Mission both in 2011
OEF: FANR's review of the operator's report on ‘Lessons Learned from Fukushima
Accident' in the context of construction licence assessment for the first NPP
The following challenges were identified for the future development with regard to
management of spent fuel and radioactive waste; Table K.6
Challenges for the UAE from
Current status
See section
the fourth Review Meeting
Concluding and commencing to
Development in this regard is
implement a comprehensive
found in section B.3
national RWM/SFM strategy in
a timely manner.
Sustainable human capacity
In-house training programme
Development for regulator is
development both for
and National programme of
found in Sections
regulatory and nuclear/non-
capacity building ongoing.
E.38-E43
nuclear sectors in line with the
Completed Radiation Safety
time frame of the strategy.
Training requirements for
And for nuclear development
Radiation workers (on FANR
see F.5-F.10.
For non-nuclear sector see E.44
Continued development and
FANR now has 18 Regulations
Development in this regard is
implementation of
and 16 Regulatory Guides
found in Sections E.8-E.9 and
comprehensive regulations and
where 5 are drafts.
regulatory guides to support
the National Strategy.
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The following UAE planned measures to improve safety were identified;
UAE planned measures to
Current status
See section
improve safety
Continuing development of
FANR-REG-24 is revised,
E.8-E.9 and
necessary regulatory and
FANR-REG-26 on Predisposal Management
organisational framework to
and its guide FANR-RG-018 are ready for
ensure the safety, security and
approval of the FANR Board.
environmental acceptability of
Regulation on Disposal under development.
Regulations on Decommissioning and
Decommissioning Fund are under
Keeping the balance between
moving forward on national
RWM strategy and keeping
more optimized and safer
International review missions performed and planned
The UAE has accepted 3 international review missions:
Integrated Nuclear Infrastructure Review (INIR) Mission, in 2011 , a Site Review Mission, in 2011, and an IAEA Integrated Regulatory Review Service (IRRS) Mission in December 2011.
More information about these missions can be found in Annex D with links to the full reports. The following review missions are planned before Barakah enters into operation:
IRRS follow-up mission (2015) Occupational Radiation Protection Appraisal, ORPAS (2015) Emergency Preparedness Review –EPREV (2015) International Physical Protection Advisory Service – IPPAS (2016) Operational Safety Review Team for pre operational phase – Pre-OSART (date to be
Planned Efforts to Improve Safety
K.9
National policy and strategy declared and implemented
The UAE government will publish the national integrated spent fuel and radioactive waste
management policy and strategy for managing of spent fuel and radioactive waste.
K.10 Waste Management Organisation appointed
The UAE government will appoint a Waste Management Organisation (WMO) for the
managing of spent fuel and radioactive waste in UAE.
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K.11 National waste management plan developed
When the WMO is appointed, work to develop a national waste management plan will be
completed.
K.12 Continued development of regulations and guides
Continue to develop regulations and guides according to the FANR Regulation and Guide
development plan which is accessible on FANR web site;
K.13 NORM Facility and disposal licensing
The application for a NORM treatment and disposal facility is still under review by FANR.
This planned facility will be the first of its kind in UAE.
K.14 International cooperation
FANR will continue to participate in peer reviews, international meeting and events, such as
the Meeting on the Convention of Nuclear Safety and Joint Convention on Spent Fuel
management and on the Safety of Radioactive Waste Management and also continue to
participate in development of IAEA Safety Standards through membership on the Standards
Committees like the Commission on Safety Standards (CSS), the Radiation Safety Standards
Committee (RASSC), the Nuclear Safety Standards Committee (NUSSC), and the Nuclear
Security Guidance Committee (NSGC).
United Arab Emirates Second National Report
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Section L. Annexes
Annex A.1
Inventory of radioactive waste
Inventory of orphan sources
References to national laws, regulations, requirements, guides, etc.
References to official national and international reports related to safety
References to reports on international review missions performed at the request of a Contracting Party
United Arab Emirates Second National Report
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Annex A – inventory of radioactive waste
A.1
FANR did a waste survey in 2011 where the following waste was declared:
Radionuclide
Quantity
Total Activity
Comments
Two sources unknown activity
There is no detail about date of measurement
Shielded with DU
Am-241/Be
There is no detail about date of measurement
Radioactive sources with short
Store until decay
half-life used in NM
Sources used for calibration and as
mixed sources & obsolete sources
Very small activity
reference
Sludge and Scales
(two companies declared)
Note: No other survey has been conducted.
A.2
Inventory of orphan sources held in storage facilities 2011-2014 (June)
No Radio-
Activity
Application
Collected from Scrap of
(BRACHYTHERAP) governmental department
Brought in Scrap from
Italy to free zone
Brought in Scrap from
Republic of Ivory Coast to
Collected from Scrap of
governmental department
government company.
Note: Orphan sources will be stored in a central storage facility
United Arab Emirates Second National Report
Under the Joint Convention
Annex B - References to national laws, regulations, requirements,
guides, etc
UAE Policy Paper: Policy of the United Arab Emirates on the Evaluation and Potential
Development of Peaceful Nuclear Energy, can be found on FANR websiteunder ‘Open data'.
All issued documents below (not the drafts) can be found on the FANR website,
under ‘Regulations and Guides'.
The FANR Regulation and Guide development plan is also accessible on FANR web site;
FANR LAW: Federal Law by Decree No. 6 Of 2009 Concerning the Peaceful Uses of
FANR now has 18 Regulations and 16 Regulatory Guides of which 5 are drafts.
FANR-REG-01, "Management Systems for Nuclear Facilities;" FANR-REG-02, "Siting of Nuclear Facilities;" FANR-REG-03, "Design of Nuclear Power Plants;" FANR-REG-04, "Radiation Dose Limits and Optimisation of Radiation Protection
for Nuclear Facilities;"
FANR-REG-05, "Application of Probabilistic Risk Assessment at Nuclear Facilities;" FANR-REG-06, "Application for a Licence to Construct a Nuclear Facility;" FANR-REG-08, "Physical Protection for Nuclear Material and Nuclear Facilities;" FANR-REG-09 "Regulation on the Export and Import Control of Nuclear Material,
Nuclear Related Items and Nuclear Related Dual-Use Items" (New)
FANR-REG-10 "System of Accounting for and Control of Nuclear Material and
Application of Additional Protocol" (New)
FANR-REG-11, "Radiation Protection and Predisposal Radioactive Waste
Management for Nuclear Facilities;"
FANR-REG-12, "Emergency Preparedness at a Nuclear Facility;" FANR-REG-13, "Safe Transport of Radioactive Materials;" FANR-REG-14, "Regulation for an Application for a License to Operate a Nuclear
FANR-REG-15 "Regulation "Requirements for Off-Site Emergency Plans for
Nuclear Facilities" " (New)
FANR-REG-16 ‘Regulation on Operational Safety including Commissioning" (New) FANR-REG-17 "Certification of Operating Personnel (New) FANR-REG-23 (Restricted) "Security of Radioactive Sources" (New) FANR-REG-24,Revision 1 "Basic Safety Standards for Facilities and Activities
involving Ionizing Radiation other than in Nuclear Facilities"
United Arab Emirates Second National Report
Under the Joint Convention
The following regulations are under development: • FANR-REG-16 "Operational Safety including Commissioning" • FANR-REG-18 "Administrative Liabilities and Penalties" • FANR-REG-19 "Regulation on existing exposure situations" • FANR-REG‐21 "Decommissioning" • FANR-REG-26 "Predisposal Management of Radioactive Waste"
FANR Regulatory Guides
Regulatory guidance that describes methods acceptable to FANR for the implementation of these regulatory requirements is also under preparation in the form of Regulatory Guides. The following table shows the regulatory guides that have been approved and issued together with draft guides:
FANR-RG-001, "Content of Nuclear Facility Construction and Operating License
FANR-RG-002, "Application of Management Systems for Nuclear Facilities" FANR-RG-003, "Probabilistic Assessment: Scope, Quality and Application" FANR-RG-004, "Evaluation Criteria for Probabilistic Safety Targets and Design
FANR-RG-006, "Transportation Safety Guide" (New) FANR-RG-007, "Radiation Safety Guide" (New) FANR-RG-010, "Identification and Maintenance of Target Sets and Timeline
FANR-RG-011, "Guidance on Cyber Security at Nuclear Facilities"(New) FANR-RG-017, "Certification of Reactor Operators and Senior Reactor Operators
at Nuclear Facilities" (New)
FANR-RG -018, "Predisposal Radioactive Waste Management (Draft) FANR-RG-019, "Radiation Safety in Industrial Radiography" (New) FANR-RG-020, "Security of Radioactive Sources in Use and Storage" (Draft) FANR-RG-021, "Security of Radioactive Sources during Transport" (Draft) FANR-RG-022, "Imminent Threats & Beyond Design Basis Threats" (Draft) FANR-RG-023,"Safety Significance Evaluations for Modifications for Nuclear
Facilities" (Draft)
United Arab Emirates Second National Report
Under the Joint Convention
Annex C - References to official national and international reports
related to safety
The following FANR documents can be found on FANR webpag
1st National Report on Measures taken by the United Arab Emirates to
implement the Convention on Nuclear Safety, August 2010.
Integrated Regulatory Review Service (IRRS) mission to the United Arab
Emirates, December 2011.
First national report on compliance with the obligations of the Joint
Convention on the safety of spent fuel management and on the safety of radioactive waste management, October 2011.
Safety Evaluation Report of an Application for a license to construct Barakah
Executive summary of Safety Evaluation Report of ENEC's Application for an
amendment to a Limited Construction License for Stage 1.
National Report to the Ex-Ordinary Meeting August, May 2012. Federal Law by Decree No. 4 of 2012 Concerning Civil Liability for Nuclear
UAE National Report for the 6th Review Meeting of the Convention on
Nuclear Safety March/April 2014.
International Advisory Board reports
The International Advisory Board (IAB) is established to provide the UAE peaceful
nuclear energy program with the benefit of the expertise and knowledge of a highly
select group of internationally recognized experts in the fields of nuclear safety and
security, non-proliferation and the development of human resources.
On at least a semi-annual basis the Board reviews the progress the UAE is making in
achieving and maintaining the highest standards of safety, security, non-
proliferation, transparency and sustainability. Board members provide their
invaluable insights into how the program can be optimized against these targets.
The
United Arab Emirates Second National Report
Under the Joint Convention
Annex D - References to reports on international review missions
performed at the request of a Contracting Party
Integrated Nuclear Infrastructure Reviews (INIR) Mission
At the request of the Government of the UAE, an international team of experts visited FANR
from 16-23 January 2011 to conduct a full scope IAEA Integrated Nuclear Infrastructure
Review Mission to provide a holistic coordinated peer review conducted by a team of IAEA
staff and international experts who have direct experience in specialized nuclear
infrastructure areas.
The full report is available at;
IAEA Integrated Regulatory Review Service (IRRS) Mission
At the request of the Government of the UAE, an international team of experts visited FANR
from 5-14 December 2011 to conduct a full scope IAEA Integrated Regulatory Review
Service (IRRS) mission to review FANR's regulatory framework and its effectiveness.
The scope of the mission included sources, facilities and activities regulated by FANR:
nuclear power reactors, industrial and research activities, safety and security of radioactive
sources, radioactive waste management, decommissioning, and remediation. Both
regulatory technical and policy issues were addressed.
The report identified; Main Observations, Good practices, Recommendations and
Suggestions. One Good Practice is "The UAE has developed, in a relatively short period of
time, a comprehensive national regulatory framework for nuclear safety. For the
establishment of its own regulatory requirements and guidance, the FANR has made
extensive use of IAEA Safety Standards. The obligation of the FANR to take account of
internationally recognized standards and recommendations, such as the IAEA Safety
Standards, when developing the national regulations and guidelines, is explicitly stated as a
mandatory requirement in the UAE Nuclear Law."
The full report of the mission is available online:
The 2011 IRRS mission was a full-scope review to assess FANR's regulatory framework and
practices against the IAEA Safety Standards. There is to be an IRRS follow-up mission to
FANR planned in 2015, to assess implementation of the 2011 IRRS recommendations.
Source: https://www.fanr.gov.ae/En/Opendata/Documents/National%20report%20by%20UAE%20for%205th%20RM%20of%20the%20JC.pdf
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