IAEA Workshop on Planning and Licensing
of Decommissioning Projects
26 – 30 November 2012, Karlsruhe
Licensing of Nuclear Facilities –
International Approaches
Joerg Kaulard, Gesellschaft fuer Anlagen- und
Reaktorsicherheit (GRS) mbH
Content
 Introduction
 International Standards
• IAEA Safety Standards
• WENRA WGWD
 Country Specific Aspects
• Focal Points
• Germany
• France
• Spain
• Your Examples
 Summary
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Introduction
 Generally accepted principle
• Any operation of a nuclear facility or conduct of any activity related to ionizing
radiation shall require a license ( authorization).
• A license represents the answer of the regulatory body that (& under which
conditions) the applied operation / conduct of an activity complies with legal and
regulatory requirements.
 Some questions related
• Need licensing processes be the same in different countries?
• What is the core (common sense) of all licensing processes?
• Is there something specific to decommissioning?
• Who are the parties involved?
 This presentation hopes to provide some insights / observations
related to nuclear power plants (research reactors)
but: it’s not a lecture on legal aspects and for sure, it is incomplete!
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Overview
 Requirements and recommendations related to authorization / licensing are
addressed in several IAEA Safety Standards, e. g.
• SF-1 – Fundamental Safety Principles (2006)
• GSR Part 1 – Governmental, Legal and Regulatory Framework for Safety
(2010)
• GS-G-1.2 – Review and Assessment of Nuclear Facilities by the Regulatory
Body (2002)
• GSG 12 – Licensing Process for Nuclear Installations (2010)
• WS-R-5 – Decommissioning of Facilities Using Radioactive Material (2006)
to be replaced soon by GSR Part 6 – Decommissioning of Facilities
(revision DS 451, September 2012)
• WS-G-2.1 – Decommissioning of Nuclear Power Plants and Research Reactors
(1999) ( revision DS 452)
• WS-G-2.4 – Decommissioning of Fuel Cycle Facilities (2001) ( revision DS 452)
• WS-G-5.2 – Safety Assessment for Decommissioning of Facilities Using
Radioactive Material (2006)
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Excerpts
 GSR Part 1 (esp. requirements 23 & 24 and details 4.29 – 4.39)
• Requirement 23: Authorization of facilities and activities by the regulatory body
Authorization by the regulatory body, including specification of the conditions
necessary for safety, shall be a prerequisite for all those facilities and activities
that are not either explicitly exempted or approved by means of a notification
process.
Note: Authorization includes approval, written permission, licensing,
certification or registration
• Requirement 24: Demonstration of safety for the authorization of facilities
and activities
The applicant shall be required to submit an adequate demonstration of safety in
support of an application for the authorization of a facility or an activity.
 4.29. Different types of authorization shall be obtained for the different
stages in the lifetime of a facility or the duration of an activity. ...
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Excerpts
 GSR Part 1 (cont’d)
• Requirement 24: Demonstration of safety for the authorization of facilities
and activities (cont’d)
 4.31. In the granting of an authorization for a facility or an activity, the
regulatory body may have to impose limits, conditions and controls on
the authorized party’s subsequent activities.
 4.33. Prior to the granting of an authorization, the applicant shall be required
to submit a safety assessment [8], which shall be reviewed and assessed
by the regulatory body in accordance with clearly specified procedures. ...
 4.35. Some of the stages in the lifetime of a facility or the duration of an
activity (see para. 4.29) may require specific hold points at which separate
authorizations are required. ...
 4.36. An authorization may have to be reconsidered and/or renewed in the
different stages in the lifetime of the facility or the duration of the activity
concerned (...). This would have to lead to a new regulatory decision which
may require the amendment, renewal, suspension or revocation of the
authorization.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Excerpts
 GS-G-1.2 (esp. recommendations 2.6 – 3.39)
• 2.6. The regulatory body should indicate to the operator the period of time
that is considered necessary for the review and assessment process so as to
facilitate the process and to minimize delays in the granting of any necessary
authorizations. It is appropriate to reach agreement on an indicative schedule. ...
... The regulatory body should expend its best efforts to complete its review
and assessment process in accordance with the agreed schedule, but this
objective should in no way compromise the regulatory body’s
responsibilities.
• 2.21. Decommissioning of a nuclear facility, such that regulatory controls may be
removed, includes decontamination and the dismantling and/or removal of
radioactive materials, radioactive waste, components and structures. ...
Just before the permanent shutdown of the facility, a detailed plan should be
prepared for authorization or approval by the regulatory body. ...
• 2.31. The operator should submit its documentation early enough to allow the
regulatory body to proceed in a timely manner with its review and assessment. ...
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Excerpts
 GS-G-1.2 (cont’d)
• 2.32. In all stages of the authorization process, the operator and the
regulatory body should continue to hold meetings to discuss topics such as
the bases for proposed changes, in advance of making formal submissions,
or to discuss matters already under consideration.
... Written records should be kept of such meetings, and of any decisions or
agreements reached.
• 2.39. Information may be exchanged by means of meetings, transfer of
documents and visits by experts, but none of these should in any way relieve
the national regulatory body of its responsibilities for making decisions and
recommendations.
• 3.16. The purpose of the review and assessment of the documented
information submitted by the operator is to enable the regulatory body to make
a decision or a series of decisions on the safety of the facility and its associated
activities.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Excerpts
 GS-G-1.2 (cont’d)
• 3.17. Decisions relating to safety should be made on the basis of
 the review and assessment of the operator’s submissions,
 the studies and evaluations performed independently by the regulatory body
itself, and
 the safety objectives and specific requirements established by the regulatory
body.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Excerpts
 DS 451 (Draft GSR Part 6)
• Requirement 4: Responsibilities of the government
The government shall establish and maintain a governmental, legal and
regulatory framework within which decommissioning, including management of
the resulting radioactive waste, can be planned and carried out safely.
... All aspects of decommissioning shall be subject to authorization and
regulatory oversight, from the siting and design of a facility to the termination of
authorization.
• Requirement 5: Responsibilities of the regulatory body
The regulatory body shall regulate all aspects of decommissioning, from the
siting and design of the facility to the completion of decommissioning actions and
the termination of authorization. The regulatory body shall establish the safety
standards and requirements for decommissioning, including management of the
resulting radioactive waste, and shall take actions to ensure that the regulatory
requirements are met.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Excerpts
 DS 451 (cont’d)
• Requirement 5: Responsibilities of the regulatory body (cont’d)
 3.3. The responsibilities of the regulatory body shall include ( excerpt):
 establishing criteria and the time frame for the commencement of
decommissioning;
 establishing the review process for decommissioning plans and
supporting documents (which are prescribed in national requirements);
 inspecting and reviewing decommissioning actions and taking
enforcement actions in case of non-compliance with the authorization
or license conditions and safety requirements derived from the national
legal framework;
 evaluating the end state of a decommissioned facility ...;
 terminating the authorization when the operator has demonstrated that
the approved end state has been met;
 giving interested parties an opportunity to provide comments on the final
decommissioning plan and supporting documents before approval based
on national requirements.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Excerpts
 DS 451 (cont’d)
• Requirement 6: Responsibilities of the operator
The operator shall implement planning for decommissioning and shall carry out
the decommissioning actions in compliance with the authorization and with
safety standards and requirements derived from the national legal framework.
The operator shall be responsible for all aspects of safety and protection of
the environmental during decommissioning.
 3.4. The responsibilities of the operator shall include ( excerpt):
 notifying the regulatory body prior to permanent shutdown of the
facility;
 submitting a final decommissioning plan and supporting documents for
review and approval by the regulatory body, in accordance with
national regulations, in order to obtain authorization for decommissioning;
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Excerpts
 DS 451 (cont’d)
• Requirement 10: Planning of decommissioning
The operator shall prepare decommissioning plan and maintain it throughout the
lifetime of the facility, unless otherwise required by the regulatory body, in order
to show that decommissioning can be accomplished safely to meet the defined
end state.
 7.5. The operator shall prepare and submit an initial decommissioning plan
together with the application for authorization to operate the facility. ...
 7.6. The initial decommissioning plan shall be updated by the operator and
shall be reviewed by the regulatory body periodically, at least every five
years or as prescribed by the regulatory body; or when specific circumstances
warrant, such as if changes in an operational process lead to significant
changes to the plan.
... If an incident occurs or a situation arises with consequences relevant for
decommissioning, the initial decommissioning plan shall be updated by the
operator as soon as possible and shall be reviewed by the regulatory body.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Excerpts
 DS 451 (cont’d)
• Requirement 11: Final decommissioning plan
Prior to conducting decommissioning actions, a final decommissioning plan
shall be prepared and shall be submitted to the regulatory body for approval.
 7.10. The operator shall inform the regulatory body prior to permanently
shutting down the facility. If a facility is permanently shut down and/or is no
longer used for its intended purpose, a final decommissioning plan shall be
submitted to the regulatory body for approval within two years of the
cessation of authorized activities, unless an alternative schedule is
prescribed by the regulatory body.
 7.11. The final decommissioning plan and supporting documents shall include
the decommissioning strategy; decommissioning actions; the proposed end
state and how the operator will demonstrate that the end state has been
achieved; the timeframe for decommissioning; and details of the funding for
the completion of decommissioning.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Excerpts
 DS 451 (cont’d)
• Requirement 11: Final decommissioning plan (cont’d)
 7.12. Large and complex decommissioning projects may benefit from having
decommissioning actions divided into several phases. All phases to reach
the end state shall be described in the final decommissioning plan and
supporting documents. Updates of the final decommissioning plan shall
include additional information for subsequent phases.
 7.13. If the final decommissioning plan or updates to it include new
technologies and concepts for decommissioning actions, the operator shall
demonstrate prior to their use that the use of such methods is safe and can
effectively achieve the desired result.
 7.14. Updates of the final decommissioning plan shall be made as necessary
in the light of experience gained in decommissioning, new or revised safety
requirements, or new or revised national regulations. Updates of the final
decommissioning plan by the operator shall be subject to review and
approval by the regulatory body.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Excerpts
 DS 451 (cont’d)
• Requirement 11: Final decommissioning plan (cont’d)
 7.17. Interested parties shall be provided with an opportunity to examine the
final decommissioning plan and, as appropriate, supporting documents, and
to provide comments prior to its approval subject to national requirements.
• Requirement 15: Completion of decommissioning actions and termination of
authorization
On the completion of decommissioning actions, the operator shall
demonstrate that the end state criteria as defined in the final decommissioning
plan and any additional regulatory requirements have been met. The regulatory
body shall verify the compliance with end state criteria and shall decide on
termination of the authorization.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – IAEA Safety Standards – Summary
 General IAEA Safety Standards require / recommend
• Licensing / authorization take into account the review of safety assessments.
• A license may contain hold points to improve the control of the regulatory body.
• Licensing / authorization and regulatory supervision are closely related.
• Regulatory body and operator should clarify prior to the application details of
the licensing process and relevant regulatory requirements and criteria.
 Regulatory body and operator should continue an information process.
 Decommissioning specific IAEA Safety Standards require / recommend
• Decommissioning (including termination of the license) shall be subject to
authorization and regulatory oversight.
• Notification prior to permanent shut down
• Submission of final decommissioning plan with 2 years after cessation.
• Early involvement of interested parties to comment on the final
decommissioning plan.
• Details on the final decommissioning plan / application documents exist.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – WENRA WGWD
 WENRA WGWD SRL version 2.1, issued in March 2012
• Address safety related requirements to be fulfilled by the operator, but
 relevant for regulatory body as they need to be considered during licensing /
authorization or supervision
 some explicitly require submission of documents to the regulatory body
• D-01: A licensee shall be responsible for all aspects of nuclear safety on the
facility. The continuity of responsibility shall be ensured throughout operation
and decommissioning.
• D-03: The ultimate responsibility for safety shall remain with the licensee,
although it is permissible to delegate the performance of specific tasks to
subcontractors. The licensee shall ensure that the work of contractors is
appropriately controlled so that it is conducted safely.
• D-20: The licensee shall submit the initial decommissioning plan to the
regulatory body in support of the license application for construction for a new
facility.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – WENRA WGWD
 WENRA WGWD SRL version 2.1 (cont’d)
• D-26: As soon as it has been decided to permanently shut down a nuclear
facility, the licensee shall inform the regulatory body.
• D-27: If a facility is shut down and no longer used for its intended purpose, a
final decommissioning plan shall be submitted to the regulatory body not
later than two years after the shutdown of the facility, unless an alternative
schedule for the submission of the final decommissioning plan is specifically
authorized by the regulatory body.
• D-52: The safety case for decommissioning and any updates of the final
decommissioning plan shall be submitted to the regulatory body.
• D-60: Before a facility or site can be released from regulatory control, the
licensee shall perform a final survey to demonstrate that the end-state, as
approved by the regulatory body, has been met.
• D-61: At the completion of decommissioning, the licensee shall not be relieved
of responsibility for the facility or site unless the regulatory body has agreed.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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International Standards – WENRA WGWD
start of phase 1
valid safety case
final shut down
start of phase 2
Safety Case for Operation
Safety Case for Decommissioning
revision of
safety case
replace safety case for op.
by safety case for deco.
safety
assessment
for phase 1
decommissioning plan
level of detail (not to scale)
start of phase 3
safety
assessment
for phase 2
revision of
safety case
safety
assessment
for phase 3
safety relevant elements
details for phase 1
details for phase 2
details for phase 3
not safety relevant elements
further details e.g. waste management plan
final decommissioning plan
update for phase 2
update for phase 3
time
(not to scale)
final shut down
start of phase 1
start of phase 2
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
start of phase 3
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International Standards – Summary
 Decommissioning actions shall be subject to a regulatory body’s licensing /
authorization resulting in
• License, approval, written permission, certification, registration.
 Licensing / authorization takes into account the results of the review of the
safety assessment as part of the application documents.
 Licensing / authorization shall involve interested parties sufficiently early
and shall follow a systematic approach.
 Specific to decommissioning at least two steps of licensing / authorization
exist:
• Related to the final decommissioning plan
• Related to the termination of the license regulating the decommissioning actions
 Some requirements exist related to the schedule of the licensing process
• Early information on the intended permanent shut down of a facility
• Submission of the final decommissioning plan within 2 years, if not specified
alternatively by the regulatory body.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – Focal Points
 What is the licensing concept?
• One license from operation / for decommissioning?
• Facility license / site license?
• Are hold points used?
 Who are the parties involved?
• Who is the applicant for the decommissioning license / authorization?
• When are interested parties involved?
• Are contractors involved in your decommissioning projects?
 Do regulatory requirements on schedules exist?
• For submission of application documents?
• For responses by the regulatory body?
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – Germany (Facilities acc. to § 7 AtG)
 Licensing concept for a multiphase approach
operational phase
post –
op. phase
residual operations and dismantling
licensing of and supervision on the decommissioning
phase 1
phase 2
phase 3
phase 4
release from
regulatory control
conventional
dismantling
dismantling of non-nuclear facilities
construction & operation of an interim storage facility for rad. waste
-5
-4
-3
-2
-1
0
1
2
3
4
5
6
7
8
9
10 11 12
year of decommissioning
• Each phase requires an individual license according to German atomic law.
• Licensing process for the 1st license has to take into account the overall
decommissioning concept.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – Germany (Facilities acc. to § 7 AtG)
 General concept of the licensing process
Other authorities of the
Land (Federal State)
Application documents
Licensing authority
of the Land
(Federal State)
Applicant /
Licensee
Experts and Expert
organizations (TÜV)
License
General public
• Opinion of BMU on
the draft of the
license
„Agreement on the
license“
• Draft of the license
• Application documents
• Evaluation reports by the
authorized experts
Other federal
offices
Federal Ministry for the
Environment,
Nature Conservation
and Nuclear Safety
(BMU)
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
Advisory bodies
(ESK, SSK, RSK)
Experts and expert
organizations
(GRS)
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Country Specific Aspects – Germany (Facilities acc. to § 7 AtG)
 Licensing concept
• One / several licenses related to a facility, no site license
 in general: additional license for clearance of the site
 process follows the approach for construction and operation licenses
• Hold points are
 represented by the licenses related to individual phases,
 if needed – laid down as license conditions,
 part of the work permit system to control the detailed planning of work actions.
 Parties involved (excerpt)
• Former operator is the applicant / licensee for the decommissioning license
• Public involvement during the licensing process
 for the first decommissioning license ( EIA) & in case of significant changes
• Subcontractors are frequently involved, but licensee remains fully responsible.
 No regulatory requirements on schedule for submission of an application /
issuing a license
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – France (INB acc. to TSN Act)
 Licensing concept
from: ASN Annual Report 2011
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – France (INB acc. to TSN Act)
 Licensing process (part 1)
from: ASN Annual Report 2011
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – France (INB acc. to TSN Act)
 Licensing process (part 2)
from: ASN Annual Report 2011
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – France (INB acc. to TSN Act)
 Licensing concept
• Basic Nuclear Installations (INB): full lifecycle is subject to specific licenses,
including one license for decommissioning ( TSN Act, Decree 2007-1582)
• License for final shut down and decommissioning is a new license (issued as an
decree by the responsible ministry):
 one part on final shut down activities: related to measures outside the nuclear
island on systems etc. no more needed
 one part on decommissioning: related to the nuclear island, to be conducted
after the final shut down activities are completed / postponed (in case of
immediate dismantling)
 specifies the final state and the timeframe to achieve it
 Note: in certain cases, defueling, decontamination, etc. may be performed
under the roof of the operation license if complying with that license and
related safety assessment
 licensing process same as siting / construction /operation of an INB.
• Final “license”: operators application for being decommissioned resulting in
ASN resolution – remove from list of INB
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – France (INB acc. to TSN Act)
 Licensing concept
• Hold points (stopping points) foreseen
 first 5 years described in detail in the decommissioning plan, further work
( major operations less details, but resulting in deadlines (hold points)
 for each hold point: regulatory review of details submitted by the operator
 Note: significant changes resulting in amendments of the license
( in-significant changes subject to “internal authorizations”)
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – France (INB acc. to TSN Act)
 Parties involved (excerpt)
• Licensee / applicant is the same as during operation
• Ministry in charge of nuclear safety
 issuing license (decree)
• Nuclear Safety Authority (ASN)
 in charge of controlling any nuclear activity in INBs
 to be consulted on all draft decrees and orders with a regulatory character
from the government and may refine those texts by technical resolutions.
• Institute for Radiation Protection and Nuclear Safety (IRSN) as main TSO
• General advisory groups (GPEs) to support ASN
• Other consultancy institutions exist ( JC Report 2012)
• Public involvement
 during preparation and before issuing of the final shut down and
decommissioning license (decree)
 during preparation of the final resolution
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – France (INB acc. to TSN Act)
 Regulatory requirements on schedules
• Notification of final shut down at least 3 years before submission of the
application
• Submission of the application for final shut down and decommissioning (incl.
dismantling plan) at least one year before intended final shut down
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – Spain (Nuclear Facility acc. to RNRF)
 Licensing concept for Jose Cabrera nuclear power plant
Ministerial order
of shutdown
2002
FINAL
SHUTDOWON
DECOMMISSIONING
AUTHORIZATION
LICENSE
TERMINATION
2006
2009
2015
Spent fuel
removal
(1 year)
Basic studies
(1 year)
PDC
PGC
PDC: Dismantling and Decommissioning Plan
PGC: Fuel Management Plan
EIA: Environmental Impact Assessment
Loading of
containers
(6 years)
(1 year)
(3 years)
Transfert to
ENRESA
PDC (Rev.0)
PGC (Rev.0)
EIA (Rev.0)
Return to
the owner
from: José L. Revilla / Olivier Lareynie
THE SPANISH DECOMMISSIONING SCENE
contribution to the 2009 FaSa Annual Meeting
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – Spain (Nuclear Facility acc. to RNRF)
 Legal background
• Law 11/2009 implies a revision of the system of responsibilities
 ... the dismantling and decommission of nuclear facilities constitute an
essential public service for which the State shall be responsible, pursuant to
article 128.2 of the Spanish Constitution”
 The Empresa Nacional de Residuos Radiactivos, S. A. (ENRESA) is
commissioned to manage this public service in accordance with the General
Radioactive Waste Plan approved by the Government.
 In this respect, ENRESA is set up as a resource and technical service of the
Administration, carrying out the functions as signed to it by the Government...”
• Pre-requisite for transfer of the responsibility are pre-dismantling activities as
 conditioning of operational radioactive waste, and
 removal of spent fuel from the reactor and spent fuel pond (otherwise an
spent fuel management plan approved by the ministry is needed).
• Transfer of responsibility goes with transfer of ownership of the facility until
termination of the decommissioning, afterwards return of ownership.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – Spain (Nuclear Facility acc. to RNRF)
 Licensing concept
• Contract between operator and ENRESA on duties and responsibilities
approved by responsible ministry
 relevant already during operation of the facility ( funding, documentation, ...)
• Transfer of ownership approved by the responsible ministry in parallel to
granting the authorization for decommissioning
• Operation permit expires (period defined in the operation permit), but
responsibility remains with operator ( shutdown statement)
• Authorization for decommissioning to be applied by ENRESA
• Authorization issued by the responsible ministry on base of a mandatory and
binding report by CSN
• Termination of decommissioning (“declaration of decommissioning” issued by
responsible ministry
 end state verified by CSN
 draft of declaration subject to “Autonomous Communities” responsible for land
planning and environment of the affected territory of the facility
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – Spain (Nuclear Facility acc. to RNRF)
 Parties involved
• Licensee / applicant is in case of NPPs different from the operator
 decommissioning licensee is ENRESA
 during operation: on a contractual base a joint responsibility of operator
and ENRESA to plan for decommissioning
• Ministry in charge of nuclear safety (Ministry of Industry, Tourism and Trade)
 issuing license / declaration
 approving contract / transfer of ownership
• Nuclear Safety Authority (CSN)
 review and preparation for license, supervision
• Public involvement – initiated by the responsible ministry
 at least before issuing of declaration: “Autonomous Communities”
 information on further involvement is missing
 Regulatory requirements on schedules
• Not known, if any
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Country Specific Aspects – Your Examples
 What is the licensing concept?
• One license from operation / for decommissioning?
• Facility license / site license?
• Are hold points used?
 Who are the parties involved?
• Who is the applicant for the decommissioning license / authorization?
• When are interested parties involved?
• Are contractors involved in your decommissioning projects?
 Do regulatory requirements on schedules exist?
• For submission of application documents?
• For responses by the regulatory body?
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Summary
 Decommissioning is subject to regulatory authorization and supervision.
• No decommissioning actions shall be performed without authorization by the
regulatory body.
• General and decommissioning specific requirements and recommendations exists
on international level by IAEA or WENRA.
 The authorization process is strongly linked to the review of safety
assessments performed.
 Different authorization concepts and processes are applied, e.g.
• Issue of one or several licenses,
• Issue of one license with foreseen hold points,
• Amendment / change of an existing license for a unit / site ( Sweden, UK),
• Transfer of responsibility from an operator to a decommissioning licensee,
• Requirements on timing for submission of an application / granting of a license
( France, US).
 Public involvement is a must and implemented in all countries discussed.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Thank You for Your Attention!
Auxiliary Information
Auxiliary Information – Content of Initial Decommissioning Plan
 Initial Decommissioning Plan according to DS 450
• 7.5 The operator shall prepare and submit an initial decommissioning plan
together with the application for authorization to operate the facility. This
initial decommissioning plan shall be required in order to ensure that sufficient
funds will be available for decommissioning, to facilitate early planning for
minimization of decontamination, to identify categories and to estimate
quantities of waste.
 Initial Decommissioning Plan according to WS-G-2.4
5.6
... The initial decommissioning plan should
• take into account basic safety issues;
• support the fact that decommissioning can be safely conducted using proven
techniques or ones being developed;
• include a generic study showing the feasibility of decommissioning;
• include consideration of environmental aspects of decommissioning, such as
management of waste and radioactive effluents;
• address the costs of the decommissioning work and the means of financing it.
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Auxiliary Information – Content of Final Decommissioning Plan
 Final Decommissioning Plan according to DS 450
• Requirement 11: Final decommissioning plan
Prior to conducting decommissioning actions, a final decommissioning plan
shall be prepared and shall be submitted to the regulatory body for approval.
• 7.11. The final decommissioning plan and supporting documents shall include
the decommissioning strategy; decommissioning actions; the proposed
end state and how the operator will demonstrate that the end state has been
achieved; the timeframe for decommissioning; and details of the funding for
the completion of decommissioning.
 Final Decommissioning Plan according to WS-G-2.4
5.12. The final decommissioning plan should include, where applicable, the
following items: (excerpt)
• facility description, incl. description of
decommissioning action
• radiological characterization
• waste management programme
• health and safety management
programs
• safety assessment
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Auxiliary Information – Content of Final Decommissioning Plan
 Final Decommissioning Plan according to WS-G-2.4
5.12. The final decommissioning plan should include, where applicable, the
following items:
•
(a) A description of the facility, the site and the surrounding area, that could affect, and be affected by, its decommissioning;
•
(b) The life history of the facility, reasons for taking it out of service, and the planned use of the site during and after decommissioning;
•
(c) Information on incidents that have occurred during the operational phase, in particular those involving spills and the release of radioactive material;
•
(d) Details of significant modifications carried out during the operational phase;
•
(e) An assessment of the amount, type and location of residual radioactive and hazardous non-radioactive materials in the facility, including calculational methods and measurements
to determine the inventories (i.e. the characterization of the facility);
•
(f) A description of the regulatory framework within which decommissioning will be carried out;
•
(g) A description of the proposed decommissioning activities, and the programme,
•
including a detailed schedule;
•
(h) The rationale for selecting the preferred decommissioning option;
•
(i) Descriptions of safety assessments and environmental impact assessments, including the potential radiological and non-radiological hazards to the workers, the public and the
environment;
•
(j) A description of the proposed environmental monitoring programme to be undertaken during decommissioning;
•
(k) A description of the experience, resources and responsibilities of the decommissioning organization, including details of the qualifications, skills and training of the
decommissioning personnel;
•
(l) A statement of the availability of any specific management, engineering and decommissioning techniques;
•
(m) A description of the proposed strategy for waste management;
•
(n) A description of the proposed programmes for radiation protection and safety to be used during decommissioning;
•
(o) A description of the criticality control programme, if necessary;
•
(p) A description of the quality assurance programme;
•
(q) A description of the measurement programme, equipment and methods to be used to verify that the site will comply with the release requirements;
•
(r) A demonstration of the adequacy of the financial mechanism for ensuring that decommissioning, including waste management, will be carried out in a safe manner;
•
(s) A description of the organizational and administrative controls;
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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Auxiliary Information – List of Reference
 International Atomic Energy Agency, SF-1 – Fundamental Safety Principles, 2006
 International Atomic Energy Agency, GSR Part 1 – Governmental, Legal and Regulatory Framework for Safety, 2010
 International Atomic Energy Agency, GS-G-1.2 – Review and Assessment of Nuclear Facilities by the Regulatory Body, 2002
 international Atomic Energy Agency, GSG 12 – Licensing Process for Nuclear Installations, 2010
 International Atomic Energy Agency, DS 451 – Draft GSR Part 6 – Decommissioning of Facilities, September 2012
 International Atomic Energy Agency, WS-G-2.1 – Decommissioning of Nuclear Power Plants and Research Reactors, 1999 (currently
under revision – DS 452)
 International Atomic Energy Agency, WS-G-2.4 – Decommissioning of Fuel Cycle Facilities, 2001
(currently under revision – DS 452)
 International Atomic Energy Agency, WS-G-5.2 – Safety Assessment for Decommissioning of Facilities Using Radioactive Material, 2006
 International Atomic Energy Agency, Safety Reports Series No. 45 – Standard Format and Content for Safety Related Decommissioning
Documents, 2005
 WENRA Working Group on Waste and Decommissioning (WGWD), Decommissioning Safety Reference Levels Report, Version 2.1,
March 2012
 Federal Ministry for the Environment, Nature Conservation and Nuclear Safety, Joint convention on the safety of Spent Fuel
Management and on the Safety of Radioactive Waste Management, Report of the Federal Republic of Germany for the Fourth Review
Meeting in May 2012, 2011
 Autorité de Sûreté de Nucléaire (ASN), Nuclear Safety and Radiation Protection in France in 2011, 2012
 France, Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management – Fourth
National Report on Compliance with the Joint Convention Obligations, September 2011
 Consejo de Seguridad Nuclear, Spain – Convention on Nuclear Safety – Fourth National Report, September 2007
 Spanish Nuclear Safety Council (Jóse L. Revilla, Olivier Lareynie), Second Meeting of the IAEA FaSa Project – The Spanish
Decommissioning Scene, 07 – 11 December 2009
 Spain, Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management – Fourth
Spanish National Report, October 2011
IAEA WS on Decommissioning, KIT, Nov. 2012, Licensing of Nuclear Facilities, J. Kaulard (GRS)
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