1. WORKSHOP ON REGULATORY REQUIREMENTS TO ENSURE SAFE DISPOSAL OF DISUSED SEALED SOURCES FOR OPERATORS AND REGULATORS 7 TH -11 APRIL 2014 AMMAN, JORDAN.

2. CASE STUDY- EXPERIENCE IN DEVELOPING AND ESTABLISHING THE LEGAL BASIS AND REGULATORY FRAMEWORK FOR DISPOSAL PROGRAMME AND FACILITIES FOR DSRS- GHANA. EBENEZER APPIAH OPARE Ghana Atomic Energy Commission Accra

3. CONTENT 1. SHORT COMMENTARY ON GHANA 2. EVOLUTION, FACILITIES AND ACTIVITIES OF GAEC. 3. RADIATION PROTECTION IN FOCUS. 4 LEGAL AND REGULATORY REGIME 5 MANAGEMENT OF RADIOACTIVE SOURCES IN GHANA 6. CENTRAL WASTE FACILITY 7. THE BOREHOLE DISPOSAL PROJECT 8. CONCLUSION.

4. SHORT NOTES ON GHANA INDEPENDENCE IN 1957,(ABOUT 57 YEARS), POP.ABT 22 MILLON POLITICAL INSTABILITY FOR A PERIOD, 1992 REPUBLICAL CONSTITUTION, PRESDENTIAL EXECUTIVE, LOOSE SEPERATION OF POWERS, ECONOMIC: AGRICULTURAL –COCOA, TIMBER, GOLD, DIAMOND, BAUXITE, MANGENESE, OIL. MANUFACTURING SECTOR NOT SO DEVELOPED LITERACY RATE HIGH PEACEFUL AND HOSPITABLE GOOD AND FAVOURABLE INVESTMENT DESTINATION FOOTBAL OUR PASSION FOLLOW US AT THE WORLD CUP.

5. Ghana Atomic Energy Commission (GAEC) was establish by an Act of Parliament (Act 204) in 1963 which has been superseded by Act 588 of 2000. The main functions of the Commission include the promotion and development of peaceful application of nuclear and biotechnology techniques to benefit Ghana. In pursuit of its goals GAEC has created 5 + 1 institutes to execute its mandate,

6. Ministry of Science, Environment, Technology & Innovation Ghana Atomic Energy Commission National Nuclear Research Institute (National Radioactive Waste Management Centre) Radiation Protection Board/ ( Independent Regulatory Authority) Biotechnology and Nuclear Agricultural Research Institute. Radiological and Medical Sciences research Institute School of Nuclear and Applied Science Ghana Space Science Center

7. Sources Radioactive sources have been in use in various sectors of the Ghanaian Economy(medicine, agricultural, industry, research) Nuclear medical – radiotherapy, diagnostics, equipment sterilization Food processing – food preservation & shelf-life extension thru irradiation Mining companies- nuclear gauges, radiography machines Brewery – nuclear gauges Oil exploration & refineries – nuclear gauges, neutron radiography machines. Construction Companies- nuclear gauges, radiography machines Smoke detectors R & D laboratories – calibration sources, gamma and neutron irradiators

8. Legal regime The Radiation Protection Board (RPB) was established in 1993 by a legislative Instrument LI 1559 as the National Regulatory Authority in Ghana. Mandate: register all radioactive sources in Ghana Issues : licenses, authorizations and permits for all activities involving radioactive sources ( e.g import, export, transport, use, operation of facilities, etc) Inspects radiation sources and facilities: Make regulations for the management of disused sealed radioactive sources (DSRS) in Ghana Develops safety Guides in respect of General management practices for radioactive sources in Ghana (the GRPB-G SERIES) Added mandate : non ionizing ; inspection of telephone mast and cell sites under the NCA law of Ghana. LI 1559 in the current stated is inadequate and should be amended but because of a New Bill and a comprehensive Regulations in the process we have not.

9. IAEA LEGAL INSTRUMENTS:CONVENTIONS, TREATIES AND PROTOCOLS. Ghana is signatory and has ratified the follow: Treaty on Non Proliferation of Nuclear Weapons Convention on Nuclear Safety Joint Convention on the Safety of Spent fuel Management and on the Safety of Radioactive Waste Management Amendment to the Convention on the Physical Protection of Nuclear Material (CPPNM) Africa Nuclear Weapon Free Zone Treaty (Pelindaba Treaty and Cairo Declaration) The Comprehensive Nuclear Test Ban Treaty (CTBT) Convention on Early Notification of a Nuclear Accident Convention on Assistance in the Case of a Nuclear Accident or Radiological Emergency Convention on Supplementary Compensation for Nuclear Damage. Non binding International Legal Instruments that Ghana should d adopt.; Code and Conduct on the Safety and Security of Radioactive Sources and guidance on the Import and Export of Radioactive Sources. We support the convention for the suppression of acts of nuclear terrorism UNSCR 1540 Of 2004.

10. CONVENTION, TREATIES CONT. IN ARTICLE 40 OF GHANA’S CONSTITUTION, WE COMMIT OURSELVES TO THE PROMOTION AND RESPECT FOR INTERNATIONAL LAW & TREATY s OBLIGATIONS AND ADHERENCE TO THE PRINCIPLES ENSHRINED IN OR AIMS AND IDEALS OF ANY INTERNATIONAL ORGANISATION WHICH GHANA IS A MEMBER. ARTICLE 73 AFFIRMS ARTICLE 40 ARTICLE 75 TALKS ABOUT RATIFICATION NONETHELESS INTERNATIONAL LAWS, CONVENTIONS AND TREATIES DO NOT FORM PART OF THE LAWS OF GHANA, ACCORDING TO ARTICLE 11. GHANA OPERATES A DUALIST SYSTEM IN THE DYNAMICS OF INTERNATIONAL LAW. INTERNATIONAL LAWS DO NOT BECOME AUTOMATIC MUNICIPAL LAWS UNTIL THEY ARE ADOPTED AND FOUND EXPRESSION IN THE DOMESTIC LAWS. E.G IN GHANA’S NUCLEAR RUGULATORY ANTHORITY BILL, SECTIONS 63 AND 64 SPECIFICALLY MENTIONS VIENNA AND PARIS CONVENTIONS LIABILITY FOR NUCLEAR DAMAGE., ETC AND CONVENTION ON SUPPLEMENTARY COMPENSATION.

11. Provisions in Joint Convention and Govt, Legal and framework GSR PT1 Preamble, Articles 1, 3,11, 18, 19, 20, 28 of the Joint Convention(Art 18, 19 require that we have laws and regulations) 36 requirements of GSR PT 1 Requirement1 talks about National policy and Strategy Presently there is National policy on Waste Management. Another Crucial requirement is an Independent Regulator.

12. There is a detailed National Policy on Waste Management and Action Plan with time line. A Bill to establish independent Regulator and also as a requirement for the Ghana going Nuclear Energy for Power. It has received cabinet approval yet to laid before parliament to consideration and passage in a law. 95 sections with 3 schedules, limitations: no power to the inspector to halt operations immediately it does not establish Waste facility., Which Ministry the Regulatory Body to be placed under is now a dilemma

13. Development of Regulations to operationalize the New Bill Technical persons dealing with Radiation Protection in Ghana are impatient and regret the delay in the passage of the New Bill. In readiness therefore a committee (which I am a member) has been set up to draft new regulations to operationalize the bill as soon as it receives Presidential Assent. The Bill in Section 91 defines the scope of the regulations. Presently you are looking at: Medical exposure, Public exposure Occupational exposure Transport, Licensing and Authorization Section 92 gives the Authority to develop guidelines, standards and procedures,

14. RADIOACTIVE WASTE, SPENT NUCLEAR FUEL AND DISUSED SEALED RADIATION SOURCE MANAGEMENT REGULATION 2014. THIS A NEW REGULATION WHICH WILL BE INCORPORATED IN THE NEW COMPREHENSIVE REGULATIONS. IT IS DIVIDED IN 7 PARTS PART 1; SAFETY AND LICENSING PART 2: MANAGEMENT OF RADIOACTIVE WASTE PART 3: MANAGEMENT OF DISUSED SEALED RADIATION SOURCES PART 4: DISCHARGES OF RADIAACTIVE EFFLUENTS PART 5: MANAGEMENT SPENT NUCLEAR FUEL PART 6: DISPOSAL OF RADIOACTIVE WASTE PART 7: GENERAL PROVISIONS

15. Radioactive Waste Management Infrastructure The National Radioactive Waste Management Centre (NRWMC), was established to carry out the following. Management of all radioactive waste generated in Ghana Establishment of facilities for management of radioactive waste Research activities to safely manage radioactive waste generated in Ghana.

16. Radioactive Waste Management Facility A Centralized Waste Storage facility has been constructed with assistance from the United States Department of Energy (GTRI Program) and the IAEA, The storage facility has  an area for receipt of the waste,  low activity/decay storage unit and  high activity waste storage unit The facility is equipped with physical protection systems that renders the stored waste materials safe and secured against intrusion, sabotage or theft (in line with the joint convention, physical protection, UNSCR 1540

17. A Centralized Waste Processing facility is currently under refurbishment. It will have an  Office accommodation and laboratory  Unit for segregation of the waste materials,  Unit for encapsulation disused sources  Treatment of liquid waste  Cementation area.

18. Central Waste Processing and Storage facility

20. Radioactive Waste Management Practice The radioactive waste management system practiced in Ghana is storage which requires resources and long term commitment. A national inventory of wastes is being compiled by the NRWMC Most of the waste in storage are legacy waste and in the form of disused sealed sources which are not covered by Return to Supplier agreement so they have to be managed in Ghana

21. Borehole Disposal Projec t Due to the half-life of the radionuclides and threat to national security, storage is considered as not a sustainable option for management of DSRS Hence the need for a disposal facility. Considering the small waste volumes of Ghana, there is the need for: - small volume repository - simple but safe technology with - economically viable concept In 2006 the Ghana expressed the willingness to exploit the Borehole Disposal Concept developed in South Africa under the IAEA TC Project for disposal of the disused sealed sources

22. Borehole Disposal Concept (BDC) A group of scientists from  National Nuclear Research Institute (NNRI) of GAEC,  Ghana Geological Survey Department,  Ghana Hydrological Services and the  Water Research Institute to study the BDC and characterize a site for its implementation in Ghana.

23. Borehole Disposal Concept

24. PROJECT PLAN FOR BDC - Phase 1 Objective: To identify and completely characterise a site for implementation of the Borehole Disposal Facility in Ghana. Outcome: Complete documentation on site characteristics Duration: 2009 - 2011

26. Activities  Review of existing document /information  Geophysical Investigation and preliminary site characterization  Updating waste inventory (software-RWMR)  Review of National Radioactive Waste Management regulation to include regulation on waste disposal  Draft Radioactive Waste Management Policy and Strategy  Draft technical specification and contract document for site investigation  Development of Project Management System  Preliminary Safety Assessment for the Borehole Disposal Concept in Ghana  Human resources development –Fellowship, Scientific visit, training course, expert missions

27. Geophysical investigations Geophysical investigation (Seismic Refraction and electrical resistivity studies) of the area was carried out; The results of their investigation indicated that; The bedrock has high compressional and shear velocities True resistivity of bedrock suggested that the bedrock is probably gneissic or granitic rocks Suggest that the bedrock rock at the site is competent and could serve the purpose Drilling must be carried out at where true high resistivity has been calculated for detailed geological investigation.

28. Safety Assessment for Borehole Disposal of Disused Sealed Sources in Ghana To produce the first iteration of a safety assessment that can be used in the development of a suitable borehole disposal facility (BDF) for Ghana taking into account the inventory to be disposed and the site characteristics. To identify the key parameters that needs to be characterised at the proposed site. To demonstrate and build confidence in the use of narrow diameter boreholes as a safe disposal concept for disused radioactive sources

29. The SA used data on the regional geology, hydrogeology and geochemical conditions and extrapolate to the site. Preliminary Screening used spreadsheet to calculate dose from direct exposure from ingestion, inhalation and external irradiation to a single disused source The screening calculations indicated that the P-32, Ca- 45, Fe-59, Sr ‑ 89, and Ir-192 sources can all be decay stored and do not need to be considered for disposal in the BDF. Radionuclides considered are Co-60, Sr-90, Cs-137, Ra- 226, Am- 241 and Cf-252

30. An individual effective dose constraint of 0.3 mSvy -1 for adult members of the public for all potential future exposures The AMBER software tool was used to implement the assessment model TypeGeosphere – ‘Aerobic Fractured’, ‘Aerobic Porous’, ‘Anaerobic Fractured’, and ‘AnaerobicPorous’ to account for uncertainty in the nature of the oxidising/reducing conditions and the geosphere flow

31. Assessment Timeframes

32. Unit inventory of 1 TBq per package 43 waste packages will be disposed, One borehole considered The total thickness of the disposal zone is 43.5 m. The total depth of the closure zone is 56.5m,

33. SA Conclusions The assessment indicates that Ghana’s current inventory of disused sealed sources appear to be capable of being safely disposed using the borehole disposal concept. An alternative disposal option needs to be found for the liquid H-3 waste Further characterisation is required of the sources and geosphere. Geosphere characterisation – two boreholes drilled to obtain data on the nature of groundwater flows (fracture vs porous), the hydraulic parameters (hydraulic conductivity, gradient, porosity), salinity and Eh conditions.

34. Project Plan For BDC - Phase 2 Objective: To carry out site specific safety and develop a safety case for implementation of the Borehole Disposal facility in Ghana Outcome: Documentation to demonstrate and build confidence in implementation of the Borehole Disposal facility in Ghana Duration: 2012 - 2013

35. Phase 2 - Activities: Detailed site characterization-geology(drilling boreholes, etc), geochemistry, hydrogeology Perform site specific safety assessment studies Development of safety case Development of the engineered design of the facility including waste package components Human resource development-regulatory aspect ( fellowship) site investigation (fellowship)

36. CONCLUSION  IAEA -AFRA Projects played major role in the development of the Waste Management Infrastructure especially in the Borehole Disposal concept  Financial constraints has slowed the progress of the Borehole Project  We are grateful to the IAEA for their assistance