COUNTRY REPORT

ON

CONTROL OF RADIATION PROTECTION PRACTICES IN PAKISTAN

PAKISTAN NUCLEAR REGULATORY AUTHORITY

(PNRA)

IAEA/RCA MID-TERM REVIEW MEETING

IAEA MODEL PROJECT RAS/9/026, RAS/9/027

Beijing, 7-11 June 2004

1. LEGISLATIVE AND REGULATORY INFRASTRUCTURE

1.1 Legislative and Regulatory Frame Work

In Pakistan the regulatory body has gone through a gradual process towards independence from the owner of the nuclear installations it regulates. The activities related to the promotion of peaceful uses of nuclear energy started in Pakistan as early as in 1955. In 1965, Pakistan Atomic Energy Ordinance was promulgated under which the Pakistan Atomic Energy Commission (PAEC) became a statutory body. According to this ordinance, all nuclear installations were owned and operated by the Federal Government through PAEC.

In 1984, the Directorate of Nuclear Safety and Radiation Protection (DNSRP) were established as the Regulatory Authority. This was however part of the PAEC. In 1990, the Pakistan Nuclear Safety and Radiation Protection (PNSRP) Regulations were promulgated. The regulations were applicable to all establishments which dealt with radioactive materials. These regulations allowed Director DNSRP to exercise powers of the PAEC viz., to specify procedures of registration and licensing and define the license fee structure.

The Government of Pakistan (GOP) had signed the Convention on Nuclear Safety in 1994. According to Article 8 of this Convention, each Contracting Party is required to establish an effective separation of regulatory functions from the promotional aspects of the nuclear energy. A complete independence from the management of the operating organization and utilities was essential for adequately exercising the control over the licensees. As a first step towards this goal, the Government of Pakistan created the Pakistan Nuclear Regulatory Board (PNRB) in 1994. The PNRB was semi-independent, from the Commission, as four of its seven members had no link with the PAEC. The executive arm of PNRB was DNSRP.

On 22nd January 2001, the Federal Government promulgated the Pakistan Nuclear Regulatory Authority Ordinance, through which the Pakistan Nuclear Regulatory Authority (PNRA) was established as an independent entity to implement nuclear and radiation safety regulations in the country and to control and supervise all matters pertaining to the safety of nuclear installations.

The New Ordinance

The Pakistan Nuclear Regulatory Authority (PNRA) Ordinance has replaced the PNSRP regulations of 1990 to provide more intrusive and effective regulation of nuclear energy. The Ordinance separates the two functions of regulating and utilizing nuclear energy in Pakistan and provides a distinct and legal identity to the regulatory authority. It also provides the PNRA with a mandate to establish and enforce national regulatory standards.

Page 1 of 14

The organizational setup of the PNRA is at an advanced developmental stage. The target is to establish a regulatory body that has sufficient staff, independent funding and legal powers for controlling, regulating and supervising all matters related to nuclear safety and radiation protection measures in Pakistan. The Authority is responsible for all the nuclear and radiation safety measures in Pakistan.

To achieve these objectives, the Authority, has been given the power to:

Make and enforce such rules, regulations orders or codes of practice for nuclear safety and radiation protection as may, in its opinion be necessary.

Plan, develop and execute comprehensive policies and programs for the protection of life, health and property against the risk of ionizing radiation.

1.2 Radiation, Transport, Waste Safety and Emergency Regulations

The following regulations have been drafted in the light of IAEA’s Basic Safety Standards (BSS-115), transport regulation TS-R-1 (ST-1 Revised), and TECDOC–1067 “Organization and implementation of a national regulatory infrastructure governing protection against ionizing radiation and the safety of radiation sources.”

Regulations for radiation protection-PAK/904. These regulations have already been submitted for the final approval of Regulatory Authority.

Regulations for licensing of radiation facilities other than nuclear installations- PAK/908. These regulations have already been submitted for the final approval of Regulatory Authority.

Regulations for the safe transport of radioactive material-PAK/916. These regulations have been submitted for further review and comments by PNRA Directorates and the licensees.

Regulations for waste management-PAK/915.These regulations have been submitted for further review and comments by PNRA Directorates and licensees / utilities.

1.3 The Regulatory Authority Organization, staffing and funding

The Regulatory Authority and is headed by a Chairman who is also the Chief Operating Officer. He is assisted by two full-time members, and seven part-time members appointment by the federal government. The seven part-time members consist of three technical members, three nominated members – one each from Ministry of Health, the Pakistan Environmental Protection Agency, and the Pakistan Atomic Energy Commission – and Director-General, Strategic Plans Division.

The Authority functions as regulatory and decision making body. The Authority makes licensee decisions for both nuclear and radiation facilities, and sets policies directions on safety and environmental issues that concern nuclear industry and the public. The Authority usually meets three to four times a year to deal with matter of policies making.

PNRA currently has approximately one hundred (100) employees including:

Scientists, Engineers, Health/Medical Physicists

Page 2 of 14

Technicians

Administration and Financial Officers

Supporting staff

Maintenance services personnel

PNRA also obtains services from external sources where it requires special expertise, mainly through advisors and consultants, placed in the private sector and with other agencies and regulatory organizations. The headquarters of the PNRA are located in Islamabad. There are three Regional Directorates; one directorate is located in Chashma, to deal with matters related to CHASHNUPP, one at Karachi to deal with matters related to KANUPP, and the third is located in Islamabad/Rawalpindi. These Regional Directorates are responsible for the implementation and enforcement of the safety regulations in their area of jurisdiction.

The funding for the execution of the responsibilities assigned to the Authority comes from the allocated budget provided by the Government. The funding may be partially supplemented through generated income from licensing and other advisory fees. The Authority has adequate financial and other resources to meet its current requirement for staff, staff training, buildings, facilities, equipment, use of consultants, etc to discharge its responsibilities and maintain its independence. Purchase of large and expensive equipment (such as cross border traffic scanners, etc.) would require supplementary funding.

1.4 Coordination and cooperation at the national / international levels

PNRA maintains a close liaison with all national organizations which are directly or indirectly involved in the execution of its responsibilities. Pakistan is also a signatory to international conventions on nuclear and radiation safety. It also participates in all IAEA Regional and Interregional activities related to the enhancement of radiation protection infrastructure in the country.

2 ACTIVITIES OF THE REGULATORY AUTHORITY

2.1 Notifications and authorization system

Pursuant to PNRA ordinance 2001, issuance of authorizations to a person (as defined in the ordinance) to perform specified activities is one of the main functions of PNRA. These authorizations are issued on the basis of review and assessment of licensee’s submissions. Depending upon the potential magnitude and nature of the hazards associated with nuclear/radiation installations, authorizations are required at various stages. PNRA Regulations PAK/904 “Regulations For Radiation Protection” establishes these requirements for authorizations and notifications procedures.

2.2 Inventory of sources

A computerized inventory of radioactive sources in the country is being maintained in the PNRA since 1990. The software is being upgraded to allow for better tracking and control.

Page 3 of 14

Regional Directorates carry out physical verification inspections periodically and also carry out assessment of safety and security measures.

Sources are physically verified by PNRA inspectors according to a checklist developed in the light of IAEA TECDOC-1113 and -1367. Efforts are made to keep a continuous track on the sources from their entry into the country till their return (export) or disposal in one of the dedicated repositories.

PNRA is planning to further strengthen its inspection and review system for specifying sources to ensure that all such sources remain under regulatory control.

2.3 Enforcement, inspection at review (compliance monitoring)

Under PNRA ordinance 2001, the regulatory authority is empowered to undertake enforcement actions relating to the findings of its regulatory inspectors and their review and assessment. To achieve this purpose, PNRA has established three Regional Directorates in the country which are empowered to inspect, review and assess a radiation facility in their area and provide recommendations to the licensee for implementation in the form of Post Inspection Report (PIR). The PIR is based on a harmonized check list for Regulatory Inspections of a radiation facility based on IAEA guides and standards.

2.4 Assessment and verification of the operational radiation programme

The PNRA Regional Directorates are fully responsible for the assessment and verification of the operational radiation programme of a radiation facility. The compliance of post inspection reports is verified by the Regulatory Inspectors after a due course of time. If necessary, a non compliance action is also taken if the post inspection recommendations are not complied with by the licensee.

2.5 Safety and Security of Sources

The safety and security of radioactive sources have been given utmost importance in the PNRA activities. Radioactive sources are under strict regulatory control so that there is very little chance that a source be lost, misplaced or stolen. A computerized inventory of radioactive sources in the country is being maintained at PNRA since 1990. PNSRP Regulations 1990 and PNRA Regulations (PAK/904) contain necessary clauses for initiating legal action in case of loss, theft or destruction of radioactive material and radiation apparatus. Operator of a facility is responsible to physically protect the sources and other radioactive materials. A safety guide for the users of sealed radioactive sources has been issued.

The regulatory inspections of the users of radioactive sources are carried out by RNSDs. These inspections also include physical verification of radioactive sources, verification of safety and security measures etc. Compliance with the recommendations is verified annually.

PNRA gets guidance from the IAEA safety guides and standards while devising its own regulations. In line with its support for the IAEA, Pakistan has conveyed to the D-G, IAEA (on 20th April 2004 through our Permanent Representative at Vienna) a non-binding political commitment for adoption of the “Code of Conduct on the Safety and Security of Radioactive Sources”.

Page 4 of 14

2.6 Control of orphan sources

Keeping in view the risk associated while handling any type of radioactive source or malevolent use of it, an action plan has been chalked out to strengthen the regulatory control. This includes the imposition of checking levels at various stages, right from the import of sources till their disposal. Clear guidelines are provided for all major aspects including acquisition, storage, transportation, emergency preparedness, dealing with loss and the disposal of radioactive sources. PNRA maintains a National Radiation Emergency Coordination Centre (NRECC) and this set-up is available for contingencies in this regard. Custom Authorities have been instructed to obtain “radiation-free” certificates from the importers of metal scrap. Mechanism has been established to track the sources from their cradle (entry into the country) to their grave (final disposal).

2.7 Communications with the Public and Quality Management System

PNRA has recently established an Information Services Directorate (ISD) for developing and enhancing good communication links with the public and other related organizations regarding the safety culture and requirements of national legislation on radiation protection. In collaboration with a major reputed educational / management institution in the country, PNRA is developing its own internal Quality Management Manual.

3 CONTROL OF OCCUPATIONAL EXPOSURE

3.1 Individual monitoring for external radiation

The Radiation Protection Regulations define the responsibilities of a licensee for establishing and implementing the technical and organizational measures that are needed for the protection of a radiation worker. Individual monitoring services – using both the TLD and film badges – are provided by a central service provider in the country. In addition to this, operators of nuclear power plants also provide the above service through their own arrangement using TLD’s. The occupational exposure record of each radiation worker has been centrally computerized and is kept available for verification of a Regulatory Inspector. Adequate management system is available with the service providers and verified during inspection of each facility. These services operate under the authorization of the Regulatory Authority. However, PNRA is looking for ways to improve and strengthen these services by encouraging other private entrepreneurs to enter this field. Thought is also being given to PNRA itself providing these monitoring Dosimetry services.

3.2 Calibration of monitoring equipment for external radiation

Radiation measuring instruments are calibrated at Secondary Standard Dosimetry Lab (SSDL) located at PINSTECH NILORE Islamabad. The laboratory maintains Secondary Standard Instruments in adequate agreement with the international measuring system and extends therapy dose level and radiation protection level calibration service to all the radio therapy institutes in the country. The radiation beam output measurement is also verified by Secondary Standard Dosimetry Laboratory personnel on country level. The SSDL also takes part routinely in various TLD postal dose inter-comparison programmes arranged by IAEA/WHO network of Secondary Standard Dosimetry Laboratories. The calibration services of protection dose level survey instruments were introduced at country level in October 1991. All the Personnel Monitors, Dosimeters (Film Badges and TLD’s) are calibrated at SSDL and calibration certificates giving details of calibrations is issued with

Page 5 of 14

every survey instrument. The Regulatory Inspector verifies the certification during inspection of a radiation facility. The SSDL intends to extend these calibration services to contamination monitors and high level therapy in near future after the availability of necessary equipment. We are very grateful to the IAEA for providing us the necessary secondary standards in this regard.

3.3 Individual monitoring for assessment of intakes of radionuclide

The central individual monitoring service provider has the capability of assessing the intake of radionuclide using both direct (whole body counter) and indirect method (Bioassay) for radiation workers engaged in handling loose radioactive material during a radiation work.. The provision of these services (viz. individual monitoring for external and internal intakes) is accredited through inter-comparison at international levels. PNRA has now allowed further upgrading of these services after assessing the quality management of these facilities.

3.4 Workplace monitoring

Under the PNSRP Regulations 1990 (Revised version PAK/904), the licensee is required to develop a workplace monitoring programme at its facility and maintain record for verification by a Regulatory Inspector during routine inspection of the facility. The workplace monitoring is carried out by using Survey Meter and Contamination Meters that are kept by the licensee. Regulatory requirements demand that these instruments are regularly calibrated at SSDL PINSTECH, and this is verified during each inspection.

3.5 Assessment of exposure to sources of natural radiation

No such system exists at the moment for the assessment of exposure to sources of natural radiation in the country.

3.6 Central dose record keeping for external and internal exposure

The central service provider is responsible for maintaining and keeping dose record of each radiation worker in the country. This record is verified by a Regulatory Inspector during the inspection of the facility. The Regulatory Authority intends to maintain a copy of the computerized individual dose record of each worker at its headquarters for ready reference.

4 CONTROL OF MEDICAL EXPOSURE

4.1Patient Protection In Diagnostic Radiology

Regulations are in place based upon BSS-115 in the area of diagnostic radiology. Lack of resources and available qualified experts is a major contributing factor to non compliance by licensees. QA and QC procedures are presently not in place though a genuine effort is being made to adopt and enforce some basic guidelines. Areas like image quality assessments, retake evaluations, and reporting burden to PNRA are being hindered due to the lack of proper QA/QC monitoring equipment and the lack of understanding on part of the licensees as to the importance of such practices. Protocols for quality management, though an inherent requirement of the PNRA regulations, have generally not been implemented by the licensees primarily due to lack of training and understanding of the safety culture philosophy. Although some guidelines are followed based upon manufacturer-supplied criteria a comprehensive TQM is not in existence. The areas of QA also includes surveys of patient

Page 6 of 14

doses, image quality assessments, and provision of guidance levels including but not limited to mechanisms for training, education of medical and paramedical personnel is inadequate. Another area of consistent shortcoming is the unavailability of qualified experts in the field of radio diagnostic physics. With such a large number of hospitals and medical centers nationwide, the enormous task of tabulating each and every facility is still a thing of the distant future. Implementation and compliance with these regulations varies widely between licensees and often is in disarray. PNRA with its limited staff and resources and lack of monitoring and QA/QC instruments, equipment, and trained workforce is doing its best and continues to strife to rectify the situation but a dedicated and continued technical and financial support from IAEA is a must for realization of these goals and objectives.

4.2Patient Protection In Interventional Radiology

Regulations are in place based upon BSS-115 in the area of interventional radiology. Most facilities falling under this category are operated by PAEC and have the required equipment and qualified staff in place for day-to-day activities. Some facilities / hospitals / centers operating in the private sector also offer such services, and due to the limited number of such facilities, PNRA is able to enforce and get partial compliance with most of the basic requirements under the regulations. It is expected that following of QA and QC procedures will enhance a safety culture. Centers which are operated by the PAEC are cooperative and are currently in the process of establishing procedures and guides which (upon approval by PNRA) will further enhance the safety and reliability of the medical exposures.

4.3Patient Protection In Nuclear Medicine

Regulations are in place based upon BSS-115 in the area of Nuclear Medicine. Most facilities are operated by PAEC. All facilities are licensed and are regularly inspected for compliance. Trained and qualified experts are available at these facilities and necessary efforts are being made to establish comprehensive QA and QC guidelines. Education and training of medical and paramedical staff is also being undertaken on an on-going basis. Most facilities do have medical physics staff on hand but radio pharmacy is a highly understaffed field.

4.4Patient Protection In Radiotherapy

Regulations are in place based upon BSS-115 in the area of Nuclear Medicine. Most facilities are operated by PAEC and some by private enterprises. All facilities are licensed and are regularly inspected for compliance. Trained and qualified experts are available at most facilities and necessary efforts are being made to establish comprehensive QA and QC guidelines. Continuing education and training of medical and paramedical staff is undertaken on an ongoing basis. Most of the safety information is disseminated via PNRA/IAEA organized workshops and in some cases PNRA staff has been sent abroad for advanced trainings and scientific visits. PNRA is making effort to help bring in radio pharmacy experts in these facilities also.

4.5 Type Approval Of Radiation Sources For Medical Use

All radiation sources – sealed or unsealed – including radiation generators for medical use are imported or produced locally under strict safety guidelines circulated by PNRA, which in turn conform to IEC and ISO standards. This ensures that only trained and qualified

Page 7 of 14

people handle such sources and that contingency plans in place in case of accidents. QA/QC guidelines should to make the safety process transparent and to help avoid accidents.

5 CONTROL OF PUBLIC EXPOSURE

5.1 Control of radioactive discharges

Regulatory provision has been made in PAK/909 for nuclear installations to prepare environmental monitoring program, however this does not cover quality management system. Concentration and discharge limits for radionuclides have been approved by PNRA for NPPs. Source monitoring and compliance with discharge and concentration limits is verified by the regional directorates of PNRA. Concentration limits for radionuclides in gaseous and liquid effluents have been prepared on the basis of BSS-115. Currently, these are awaiting final in-house approval.

5.2 Environmental and food monitoring

The major likely sources of public exposure are the operation of nuclear power plant, nuclear fuel cycle and the waste generated by the radio therapy and the nuclear medical centers in the country. A wide network of environmental and food monitoring has been established in the country by the major nuclear energy promoter i.e. PAEC. Similarly, under the radiation protection regulations, each nuclear facility/center is required to establish its own environmental monitoring programme and keep surveillance over the releases made by / from it. Each establishment develops its own derived release limits based on the public dose of 1 mSv/year which is verified by PNRA inspectors. PNRA has also initiated steps towards development of its own capabilities for environmental monitoring to meet the emergency preparedness and planning requirements. This will also be useful to cross check and verify the annual environmental monitoring results submitted to the authority by the licensee.

PNRA carries out food monitoring programme to assess radioactive contamination in food before issuing of a Radiation Free Certificate to the exporters of food items.

5.3 Control of Exposure to Radon

No such mechanism for the control of exposure of Radon exists in the country at the moment. However Research and Development programme for this activity is under way at one of the major research institutes (PINSTECH). However, in a nuclear fuel facility, there is a local monitoring programme for control of exposure to the radiation worker from Radon.

5.4 National waste management strategy

Regulations on Radioactive Waste Management (PAK/915) are in the final stage. These regulations are in consistent with the IAEA Safety Fundamentals publication “The Principles of Radioactive Waste Management”. Under these regulations, development of new disposal facilities shall be under the regulatory control of PNRA. Regulations allocate responsibility to the licensee for all aspects of safety of radioactive waste management.

5.5 General safety provisions for radioactive wastes

Acceptance criteria and quality management system have not been developed so far; however, the provision for waste management and storage or disposal has been provided in

Page 8 of 14

the regulations. Waste classification has been established in the draft waste management regulations. Spent sealed sources are adequately processed, stored and disposed of under regulatory control.

5.6 Treatment of radioactive waste

The procedures for the characterization and segregation of radioactive waste are normally prepared by the licensee in accordance with the PNRA requirements. Provision has been made in the draft regulations for the processing of radioactive waste to be performed adequately to fulfill acceptance requirement for disposal as well as requirements for handling, transport and storage of waste packages.

5.7 Control of discharges from the managements of radioactive wastes

Under PNRA Ordinance 2001, no person may discharge or dispose of radioactive waste to the environment without obtaining authorization from PNRA. Criteria for discharges need to be developed. There are usually administrative provisions in each facility to prevent unplanned or uncontrolled release. The facility operator/licensee is required to inform PNRA promptly if discharges exceed authorized discharge limits.

5.8 Clearance Regime by radioactive waste

Draft Regulations on Radiation Protection define clearance. Conditions and clearance levels for gaseous, liquid and solid waste are still to be developed to enable the removal from control of materials containing low levels of radionuclides.

5.9 Storage of radioactive waste

Radioactive waste is stored safely and can be retrieved (in the future) whenever disposal is authorized. Clearance for disposal as ordinary waste has so far not been allowed. Interim storage facilities are centralized on a minimum number of sites (currently only three). Regulations for site evaluation of storage facilities however do not exist. Instead, IAEA Guides and Standards are followed. At each facility, the licensee is required to allocate a clearly demarcated and dedicated area and provide controlled access to the same for the storage of radioactive waste. Safety of existing storage facilities is ensured through inspections and this is upgraded to the extent necessary.

5.10 Disposal of radioactive waste

No disposal facility exists in the country as yet. Development of such facility is under process and is the initial stage of site selection. According to the draft regulations on waste management, the licensee shall have overall responsibility for the safety of the disposal facility and shall carry out safety assessments. Regulatory requirements for the siting, designing, construction, operation, closure and post-closure of a waste disposal facility will need to be established, but currently we continue to follow the IAEA Guides and Standards on the subject.

5.11 Decommissioning of waste management facilities and radioactive waste from the decommissioning of nuclear and other facilities

As previously pointed out, Pakistan does not have a waste disposal facility and an assessment has not been made for the waste likely to be generated from the decommissioning of nuclear and other large facilities. Work on the regulations on decommissioning of nuclear

Page 9 of 14

installations is underway, and will cover the safe management of radioactive waste generated as a result of decommissioning activities. These draft regulations will ensure that sufficient capacities exist for storage and/or disposal of these wastes. The regulatory requirements for decommissioning of storage facilities and closure of disposal facilities will eventually also need to be developed.

5.12 Rehabilitation

PNRA has not made any assessment for potential risk posed by radioactive residues from past practices primarily because there are few – if any – such residues. Regulatory requirements for the safe management and cleanup of the affected areas and facilities will eventually be developed.

6 TRANSPORT SAFETY

6.1 National competent authority for the safe transport of radioactive material

Chairman, PNRA is the designated national Competent Authority for the safe transport of radioactive material. PNRA has earmarked appropriate resources and efforts are underway to improve the transportation of radioactive material in the country. It is likely that a research contract may be issued to a university for studies in this regard.

6.2 Coordination and cooperation at national and international level

Presently, PNRA does not have any formal agreements/arrangement for co-ordination with national/international regulatory authorities in the field of transport of radioactive material. However, PNRA is following the latest IAEA transport regulations (TS-R-1). Our own national emergency regulations are being drafted. These will dictate the measures, responsibilities, role etc., of the consignor/carrier in case of accidents during transport of radioactive material.

6.3 Compliance assurance programme

Pakistan normally imports most of the radiopharmaceuticals and radioactive sources needed for industrial and research applications. Under the PNSRP regulations 1990, the licensee is required to first obtain a No Objection Certificate (NOC) from PNRA for the import/export of radioactive material / sources. These NOCs dictate that the licensee has to follow the IAEA transport regulations / national requirements for the transport of radioactive material. Our regional Directorates carry out inspections of such consignments / shipments to ensure that all the requirements are met regarding transport of radioactive material locally and internationally.

7 PLANNING FOR AND RESPONSE TO RADIATION EMERGENCIES

7.1 National level arrangements for emergency preparedness and response

In Pakistan, the Federal Government is responsible for the overall management, co-ordination, control, mitigation and liquidation of consequences from disasters, accidents and

Page 10 of 14

calamities. The Pakistan Government has extensive emergency response plans for dealing with different types of national emergencies. In addition to overall national emergency plans, there are supporting plans at the provincial, district and local level. For co-ordination and execution of protective measures, a National Crisis Management Cell (NCMC) is established in Islamabad which works under the Cabinet Secretariat, Government of Pakistan.

Specific requirements on nuclear safety and radiation protection matters are regulated by the Pakistan Nuclear Regulatory Authority (PNRA). PNRA is anticipated to play a significant role in the national arrangements for response to a nuclear emergency. In case of a nuclear accident or radiological emergency, the Chairman PNRA acts as an advisor to the Government of Pakistan on actions undertaken to mitigate the consequences of the nuclear accident or radiological emergency situation. PNRA functions include keeping Chairman PNRA briefed on the emergency situation so that he can provide accurate advice to the Government of Pakistan. The PNRA has established a National Radiation Emergency Co-ordination Centre (NRECC) for receipt and dissemination of information in response to nuclear accidents or radiological emergencies happening domestically or abroad. The NRECC co-ordinates radiological monitoring in support of licensees and other off-site authorities. PNRA has internal procedures for the conduct of operations of the NRECC.

In Pakistan the national emergency response plan to combat nuclear accidents or radiological emergencies has been drafted. Efforts are under way at ensuring proper integration of PNRA with the already existing disaster response infrastructure maintained by NCMC and to make it a part of the overall national emergency plan.

7.2 Emergency preparedness and response for licensed facilities and practices

PNRA Ordinance 2001 provides the basis for establishment of regulations and guides on emergency planning and preparedness for nuclear accidents or radiological emergencies in Pakistan. Promotion or adoption of regulations and guides is on the basis of international Conventions, IAEA Basic Safety Standards and requirements such as GS-R-2 “Preparedness and Response for a Nuclear or Radiological Emergency.”

PNRA is in the process of developing or revising additional regulations and guides to regulate licensee activities in relation to emergency planning and preparedness. For example, the draft of PAK/914, Rev. 0, “Regulation on Nuclear Accident or Radiological Emergency Management” has been prepared and presently is under departmental review. The PNRA is also in the process of coordinating interfaces for prevention and management of nuclear accidents or radiological emergency situations among the Federal government infrastructure.

The licensee i.e. PAEC which is the sole promoter of safe use of nuclear energy in Pakistan is well aware of the requirements and its facilities including Karachi Nuclear Power Plant (KANUPP) and Chashma Nuclear Power Plant (CHASNUPP) maintain well documented and operational On-Site as well as Off-Site emergency plans. In the event of an emergency situation at the facility, the licensee, in accordance with its on-site emergency plan, will activate its emergency organization. Activation of the off-site emergency organization will be in accordance with the off-site emergency plan.

7.3 Medical preparedness for emergencies

Page 11 of 14

PNRA regulations PAK/913 (Rev. 1), includes provisions for emergency preparedness;. Section 2.26 (iv) of these regulations states that the emergency plan of the licensee shall include: “Provisions for minimizing the exposure of individuals to ionizing radiation and for ensuring medical treatment of casualties…”. PNRA has made educational awareness presentations regarding nuclear matters to schools, medical doctors and district health officials. PNRA also provide DNSRP/PAEC radiation information brochure to various organizations and members of the public. The licensee has the capability and equipment to implement actions to meet this requirement and the PNRA verify the licensee’s actions Both the licensee and the PNRA have stocks of potassium-iodide (KI) medication, which can be provided in an emergency to individuals that may be exposed to the radioactive plume during the early phase of a large radioactive material release from a nuclear power plant.

8 EDUCATION AND TRAINING (E&T)

8.1 E&T of persons with comprehensive responsibilities in radiation protection.

The available manpower in radiation protection has a lot of experience in the field of radiation protection. Entry-level professionals have been imparted training in the field through one year or two years course through conducted at PAEC’s major training institutes viz. PIEAS and KINPOE. They are well versed in handling the safety aspects related to the radiation practices in the country. PNRA has established its own training institute where appropriate retraining / refresher courses will be conducted in near future.

8.2 E&T of manager and workers

There is no exclusive training programme for the education and training of managers, workers and medical officers in the authorized facilities in the country. Thus, the education of these personnel in radiation protection is carried out through delivering lectures / holding short duration seminars and workshops in the country. Once the PNRA training policy is fully established in its human resource directorate, it is planned to hold comprehensive programme for the training of above personnel in the very near future.

8.3 E&T of medical and paramedical professionals

No such facilities exist at the general university level for education and training of medical and paramedical professionals in the country. In recent years, PIAES has started post-graduate degree courses in the field of nuclear medicine and medical physics. This has helped in promoting the necessity of radiation safety to medical and paramedical professionals. According to PNRA’s training policy, it is planned to hold separate short term courses in the field of nuclear and radiation safety for medical professionals in our own training institute. Often, the medical and paramedical staff (of licensees) involved in handling radioactive sources / radiation generators are imparted training / awareness through personal counseling during regulatory inspections, provision of necessary literature on radiation protection and through arranging short duration on the job training. PNRA has made it obligatory for all nuclear and radiotherapy centers to engage a qualified radiation officer / medical physicist for each of these medical centers and their presence is verified by regulatory inspectors during inspection of these centers. It is worth mentioning that almost all the large medical centers and hospitals now have qualified radiation protection personnel on their staff.

Page 12 of 14

8.4 Training of peripheral persons

Currently there is no specific regulatory requirement for the training of peripheral persons. A comprehensive training policy in the field of radiation protection awareness has to be framed. However, for many years the Ministry of Commerce has imposed a restriction on the import and export of radioactive material. The requirement of obtaining a no objection certificate (NOC) from PNRA for engaging in the above activity is mandatory under radiation protection regulations, and the peripheral persons involved at custom offices, firefighting offices etc, are aware of the regulatory requirement. These personnel have been provided necessary radiation safety advice in the handling of radioactive containments through pamphlets entitled “safe handling of radioactive material”.

9 CONCLUSIONS

Although the existing radiation protection infrastructure is meeting the basic statuary requirements of the country under existing country regulations, considerable improvements are needed to make it more efficient. Radiation is a very vast field and requires accuracy and precision at every stage of its application. The need for proper training of personnel, studies and the importance of up-to-date information cannot be but emphasized. Pakistan has limited resources at its disposal. Assistance from IAEA for improvement in the following disciplines would be welcome:

Quality Assurance/Quality Control system for diagnostic radiology and radiotherapy. (Milestone-3)

Immobilization techniques for radioactive waste. (Milestone-4)

Measurement of patient dose during Radiotherapy and assessment of chromosome aberration thereafter. (Milestone-3)

Radiation protection in diagnostic radiology. (Milestone-3)

Development of standards for verification of available calibration facilities in the nuclear medical centers. (Milestone-3)

Page 13 of 14