Workshop Proceedings · Planning for decommissioning has already commenced ahead of the first...

Workshop Proceedings

WENRA Workshop on Regulatory Aspects of Decommissioning

Berlin, 5-7 November 2019

WENRA Workshop on Regulatory Aspects of Decommissioning Berlin, 5-7 November 2019

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Contact:

Stefan Theis (chair of WENRA WGWD) [email protected]

Matthias Hackstein (local organizer BMU) [email protected]

Sven Keßen (rapporteur) [email protected]

http://www.wenra.org/decom2019/

mailto:[email protected]




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Welcome Address by Svenja Schulze (Federal Minister for the Environment, Nature Conservation and Nuclear Safety,

Germany)

Ladies and gentlemen,

In recent years, WENRA’s importance has steadily grown.

In addition to the original western European countries,

e.g. Ukraine, Russia, Canada and Japan are today also

represented in WENRA. This shows that WENRA’s work is

widely recognised and valued, even far beyond Europe’s

borders.

The large number of international participants in this

workshop highlights the growing interest around the

world in WENRA’s activities: more than 20 countries are

represented here today. This allows us to have an

intensive dialogue across national borders, which is

crucial for a sound set of rules and regulations on the

decommissioning of nuclear power plants. I am delighted

to have all of you here today.

As you know, Germany is phasing out nuclear power. The safety of our nuclear power plants has to be

guaranteed up to the very last day of operation. However, operators must continue to ensure the

highest possible level of safety during post-operation, decommissioning and dismantling of nuclear

power plants. I am therefore glad that this important issue is addressed in the workshop.

I believe that the international exchange of ideas contributes significantly to enhancing nuclear safety

around the world. Even though Germany is phasing out nuclear energy, it will continue to take on an

active role in the ongoing development and improvement of nuclear safety. I can assure you that my

colleagues and I will play a constructive part in this process also in the future. We are looking forward

to continuing our close cooperation.

Yours sincerely,

Svenja Schulze


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Table of Contents

Welcome Address

by Svenja Schulze, Federal Minister, BMU, Germany ___________________________________ 3

Table of Contents _________________________________________________________________ 4

Site visit at Greifswald NPP decommissioning project _____________________________________ 6

Opening Session __________________________________________________________________ 9

WENRA Introduction

(Mina Golshan, ONR, United Kingdom) _______________________________________________ 9

International Safety Standards as a basis for the development of national regulations for

decommissioning (Nelli Aghajanyan, IAEA) __________________________________________ 11

Regulatory Aspects in Decommissioning: Experiences in Germany and Outlook

(Wolfgang Cloosters, BMU, Germany) ______________________________________________ 12

WENRA WGWD – How the SRLs work

(Stefan Theis, ENSI, Switzerland, Chair of WENRA WGWD) ______________________________ 13

WENRA WGWD – How SRLs are implemented and how “newcomers” benefit

(Tamara Suschko, SNRI, Ukraine) __________________________________________________ 14

Session 1: Decommissioning Strategies and Planning____________________________________ 15

Development of Rostechnadzor recommendations for planning of decommissioning during

operation of nuclear facilities (Danila Savin, SEC NRS) _________________________________ 16

The need for a sustainable decommissioning paradigm

(Kristina Gillin, Lloyd’s Register) ___________________________________________________ 17

Waste management and decommissioning strategies

(Vincent Cloître, Dorothée Conte, ASN, France) _______________________________________ 18

Graded approach of regulation for decommissioning – Considerations on the concepts: risk

informed, cost benefit analysis and reasonably practicable (Alain Ensuque, ENISS) __________ 19

Session 2: Regulatory Experience ___________________________________________________ 21

Inspection practice for NPP in decommissioning

(Theo Neuffer, UM BW, Germany) _________________________________________________ 22

Enabling Regulation – The Operator’s View

(Phil Hallington, Sellafield Ltd) ____________________________________________________ 23

Decommissioning authorization process and controls in Italy

(Fabrizio Trenta, ISIN, Italy) _______________________________________________________ 24

Authorization for and regulatory control of decommissioning in Sweden

(Martin Amft, Christoffer Forss, SSM, Sweden) _______________________________________ 25

Licensing Procedure and Inspection Fields in Decommissioning of Swiss NPP

(Klaus Germerdonk, ENSI, Switzerland) _____________________________________________ 26


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Session 3: Limits of Harmonization and Specific Approaches ______________________________ 27

Harmonization challenges during WGWD benchmarking

(Stefan Theis, ENSI, Switzerland, Chair of WENRA WGWD) ______________________________ 28

Site decommissioning by dedicated decommissioning licensee: a US approach

(Corey DeWitt, Holtec) __________________________________________________________ 29

Decommissioning of the MZFR

(Ulrich Scholl, KTE) ______________________________________________________________ 30

Digitalization for Knowledge Management in Decommissioning

(Joaquin Toubes Tova, Tecnatom) _________________________________________________ 31

Session 4: Transition from Operation to Decommissioning _______________________________ 33

EDF Energy Planning for Decommissioning during Operation

(Jim Kershaw, EDF Energy) _______________________________________________________ 34

Lithuanian regulatory policy, challenges and activities during transitional period from operation

to decommissioning of Ignalina NPP (Saulius Stravinskas, VATESI, Lithuania) _______________ 35

The Development of Transition Period Requirements in the Slovak Republic

(Miroslav Drahos, UJD, Slovak Republic) _____________________________________________ 36

NEA Regulators’ Forum – Outcomes of RF/WPDD Workshop on Regulation of Decommissioning

(Mario Dionisi, ISIN, Italy; Martin Brandauer, NEA) ____________________________________ 37

Session 5: Final Stages of Decommissioning ___________________________________________ 39

End state requirements for waste and site

(Henrik Efraimsson, Åsa Zazzi, Martin Amft, SSM, Sweden) ______________________________ 40

Immediate dismantling and complete clean-out principles

(Coralie Ravier, ASN, France; Patrice François, IRSN) ___________________________________ 41

Recent developments in the regulation of UK nuclear sites in the final stages of

decommissioning & clean-up (Simon Morgan, ONR, United Kingdom) _____________________ 43

Closing Remarks

by Stefan Theis, ENSI, Switzerland, Chair of WENRA WGWD _____________________________ 44

Appendix A: Workshop Agenda _____________________________________________________ 46


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Site visit at Greifswald NPP decommissioning project

On 5 November, the day before the start of the Berlin workshop, participants of the workshop travelled

to Greifswald to visit EWN Entsorgungswerk für Nuklearanlagen GmbH (EWN). The company is located

at the site of former Greifswald NPP, East Germany’s largest nuclear power plant at its time and

projected then to consist of 8 units. 4 of them were operational in 1990, unit 5 had begun with trial

operations. After German reunification and the subsequent shutdown of all East German NPPs, EWN

was founded as a publicly owned company for the decommissioning of these NPPs. Today, EWN group

is also tasked with the decommissioning of the prototype pebble-bed reactor in Jülich and the pilot

reprocessing plant in Karlsruhe, both in the Western part of Germany. The technical tour was organised

by BMU and EWN, and staff of EWN was cordially guiding the participants around, after Gudrun

Oldenburg of EWN had given an overview of the site’s history and layout, followed by a lively discussion

with the participants.

To facilitate the decommissioning of the East German NPPs, EWN constructed an extensive

infrastructure for the processing and storage of radioactive waste at the Greifswald site. The Interim

Storage Facility North (ISN), in particular, encompasses eight halls for the storage of spent fuel and

heat-generating as well as low and medium level radioactive waste, a total of 585 tons of spent fuel

and vitrified waste and ca. 27,000 tons of other radioactive material. To ensure the continued safe

storage of the spent fuel and heat-generating radioactive waste until the availability of a disposal

facility for these waste types, a new storage facility (called ESTRAL) is in the process of commissioning

next to the current ISN building. Low and medium level waste are, for the most part, foreseen to be

disposed of in the Konrad disposal facility, with its projected start of operation in 2027.

View of the steam generator within unit 6 of former Greifswald NPP © EWN GmbH


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At the site, the participants had the opportunity to get a close look at the decommissioning of unit 6

of Greifswald NPP. Before cancellation of the project in 1989, the unit’s construction was almost

finished, but was stopped before nuclear fuel had been loaded into the core thus creating a virtually

ready-to-go nuclear power unit to visit without any radiologic concerns. The tour continued with the

ISN building where participants were shown the stored steam generators and the conditioning

installations. Participants used the occasion to discuss questions regarding the facility and its future,

e.g. the extended duration of storage for spent fuel in Germany, effects of the sea-water on the coast-

sited facility, and possibilities of further non-nuclear use of the buildings once the radioactive waste

had been shipped of for disposal.

WENRA and BMU want to express their gratitude to EWN for the possibility of visiting its Greifswald

site and for the time and efforts provided by all EWN staff.

The slides of Gudrun Oldenburg’s presentation can be found in the full version of the Proceedings.

The annulus housing the six main circulation pumps within unit 6 © EWN GmbH


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Opening Session Chair: Christine Wassilew (BMU, Germany)

I.

WENRA Introduction Mina Golshan (Deputy Chief Inspector, ONR, United Kingdom)

We are here for a working-celebration of the 20th

anniversary of creation of WENRA, focusing on

decommissioning and waste management, a key area

that WENRA has championed for almost as long.

Over the past 20 years, WENRA has made a significant

contribution to nuclear safety worldwide:

• The WENRA Reference Levels have set a high

standard of safety and brought consistency of

approach amongst WENRA member states;

• WENRA’s initiatives to subject key fundamentals to peer review has resulted in the

development of more robust approaches to emergency arrangements and response

capability;

• More recently, as a strategic partner to the European Commission, WENRA is reviewing

arrangements for ageing management as many of our nuclear facilities have now been in

service for well over two decades.

This workshop is another timely initiative - with more than 200 reactors worldwide either in, or

approaching decommissioning and many other operations and facilities coming to their end of life, it

is time that as the WENRA community we focus on decommissioning and its regulation.

We have come a long way since the first generation of nuclear power plants and fuel cycle facilities

were designed; today we expect to see decommissioning considered as part of the design and during

the operation of any nuclear facility. However, despite all the progress we have made, most of us are

at the beginning of a long road, dealing with the legacy of the first generation. Some of us are dealing

with unique challenges - as we will hear during the course of this workshop.

To be clear, this is not ta criticism of our predecessors - quite the contrary, they were the trail blazers,

esteemed scientists and engineers that pushed the boundaries to help the society benefit from what

this industry offers. Their focus though at that time was ‘there and then’ and it was decided to leave

decommissioning challenges for another day. Today, we cannot afford to do that and neither should

we seek to. That is why as we celebrate our achievements so far and reflect on the learning, we should

also recognise that being satisfied with gradual progress is no longer good enough given the scale of

the challenge we face.

Operators, supply chain and regulators, we need to ‘up our game’ and aim for a step change - this is

our collective responsibility to enable safe, timely and sustainable decommissioning. That is not to say

that we overlook the safety fundamentals that have served us for many years, but it is about being

innovative in our thinking, our processes and the use of technologies at our disposal to accelerate

decommissioning and waste remediation. This is about expanding our horizons, learning from each

other as well as other industries with similar challenges.


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Taking this approach, aiming for a step-change, is no longer a “nice to do”, it’s now a necessity, because

that is the only way we can ensure that we maintain, and in some cases, regain the confidence of the

public in what we do. In so achieving, we ensure that future generations can also benefit from what

this industry has to offer.

As regulators, we play a pivotal role, in setting and standards and securing their implementation. As

we do so, we must also be clear in our expectations of what is safe enough and what is over-

conservative in the context of decommissioning. Because over-conservatism will hold back progress.

We must not allow ‘the Best, to become the enemy of the Good and of progress’.

Ladies and Gentlemen, I wish us all a constructive workshop and fruitful discussions.


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II.

International Safety Standards as a basis for the development of national regulations for

decommissioning Nelli Aghajanyan (Division of Radiation, Transport and Waste Safety, IAEA)

Decommissioning is the last phase in the lifetime of an authorized

facility and it comprises administrative and technical actions taken to

allow the removal of some or all of the regulatory controls from a

facility. It typically involves decontamination and dismantling of

systems, structures and components of the facility, but also might

involve demolition of building structures and site clean-up.

The International Atomic Energy Agency (IAEA) is the focal point for

coordination of international cooperation in relation to peaceful use

of nuclear technologies and nuclear energy, nuclear safety and

security, and protection of people and the environment from harmful

effects of ionizing radiation. The IAEA develops and maintains a set of

international Safety Standards, applicable to different facilities and

activities, that reflect an international consensus on what constitutes

a high level of safety for protecting people and the environment. The

Safety Standards cover, among other topics, decommissioning of facilities. In addition, the IAEA

implement numerous activities and projects to assist Member States with application of Safety

Standards.

This presentation provides an overview of the structure and status of the IAEA Safety Standards on

decommissioning, and describes recent developments related to revision of existing Safety Standards,

with an emphasis on regulatory perspectives in the planning for, in the implementation of and in the

completion of decommissioning actions, taking into account the principle of the graded approach to

regulation.

Furthermore, the presentation addresses some complementary IAEA activities to assist Member

States, such as (i) providing model regulations that may be used as a basis for either developing new

regulations on all aspects of safe decommissioning of facilities or for the assessment of the adequacy

of existing regulations and regulatory guides on decommissioning, and (ii) developing specialized

training modules and providing training courses specific to safe decommissioning of facilities, e.g. on

Regulatory Control of the Decommissioning of Facilities to support the needs of regulatory bodies and

their technical support organizations. In addition, the specialized training modules are developed on

Decommissioning Planning and Project Management, on Characterization to Support

Decommissioning and on Safety Assessment for the Decommissioning of Facilities that are targeted at

relevant national organizations in Member States engaged with these tasks.


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III.

Regulatory Aspects in Decommissioning: Experiences in Germany and Outlook Wolfgang Cloosters (Director-General, BMU, Germany)

In Germany, the phase-out of nuclear energy was initiated in 2000 by

the consensus on atomic energy policy and subsequently enshrined

in the Nuclear Phase-out Amendment Act in 2002. Following the 2011

Fukushima disaster, this phase-out was further consolidated and

accelerated in a broad political and social consensus. Fixed dates for

the shutdown of German nuclear power plants were laid down in the

Atomic Energy Act for the first time. Eight power plants were

immediately shut down in 2011. Others followed over subsequent

years. The last German nuclear power plant will be shut down by

2022 at the latest.

Over the last few years we have concluded a number of licensing

procedures for the decommissioning and dismantling of nuclear

power plants: 8 procedures in 2017 and 2018 and this year for

Gundremmingen Unit B.

This talk intends to provide an insight into the licensing procedure, the competences of the

participating authorities as well as the relevant legislative and sub-legislative requirements and

recommendations for decommissioning in Germany.

Special attention will be given to the role of guidelines in the legislative framework in Germany. While

decommissioning guidelines are not legally binding on third parties, they are drawn on by licensing

authorities in licensing procedures. In this way, the guidelines contribute to the current state of the art

in science and technology in German sub-legislative regulations and thus help maintain a high standard

of safety in the decommissioning of nuclear facilities.


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IV.

WENRA WGWD – How the SRLs work Stefan Theis (Head of Predisposal Department, ENSI, Switzerland; Chair of WENRA WGWD)

According to the WENRA policy statement WENRA countries commit

themselves to implement in their regulatory practice a comprehensive

set of safety reference levels (SRLs) which is understood as the agreed

minimum level of safety requirements which should be fulfilled by

licensees in any WENRA country. WENRA countries are expected to

implement these SRLs not on a case by case basis, e.g. as individual

license conditions, but in the generally applicable parts of their

regulatory systems, such as act, ordinance or mandatory regulatory

guide.

Member states are requested to demonstrate the SRL-implementation

in a self-assessment which is later on benchmarked in a panel session or

sub-group-session of the corresponding WENRA working group.

Identified needs for improvement are listed in a national action plan and

corrective actions presented to the WGWD later on.

The WENRA working group on waste and decommissioning (WGWD) has established 4 reports:

• Waste and spent fuel storage report (including part 3)

• Disposal report (only part 1 and 2, part 3 in preparation)

• Waste processing report (only part 1 and 2)

• Decommissioning report (including part 3).

All reports are structured in a similar way, in 4 or 5 safety areas each of which consists of a number of

safety issues the intention being that SRLs of corresponding safety areas and issues are formulated in

the same way in all reports.

Whilst early versions of the reports contain only a general part 1 and a part 2 with the SRLs, later

versions of the reports include a part 3 with detailed descriptions of the benchmarking results and the

improvements initiated in executing the national action plans of each individual country.

The decommissioning report contains 62 SRLs in the following four safety areas:

1. Safety Management (14 SRLs)

2. Decommissioning strategy and planning (15 SRLs)

3. Conduct of decommissioning (20 SRLs)

4. Safety verification (13 SRLs)

In the presentation the process of defining the SRLs, the benchmarking exercise and the results of the

national action plans will be explained.


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V.

WENRA WGWD – How SRLs are implemented and how “newcomers” benefit Tamara Suschko (SNRI, Ukraine)

In 2015, the State Nuclear Regulatory Inspectorate of Ukraine (SNRІU)

has become a member of the Western European Nuclear Regulator’s

Association (WENRA). Ukrainian legal and regulatory framework in the

field of nuclear energy use, including radioactive waste management

are quite comprehensive but need further improvement.

The SNRIU harmonizes its regulations with the requirements of the

European Union, IAEA recommendations, WENRA safety reference

levels. Membership in WENRA and participation in WENRA’s working

group encourages SNRIU to develop new regulations and revise existing

regulatory acts.

WENRA’s reports with Safety Reference Levels and benchmarking

procedure is a good mechanism to improve national regulations.

The only nuclear power plant in Ukraine that is under decommissioning is Chornobyl NPP. The license

for the decommissioning of the Chornobyl NPP was issued by the SNRIU in March 2002. For Chornobyl

NPP it was accepted deferred dismantling strategy, which supposes the following stages: shutdown

stage (cessation of operation), final shutdown and preservation, safe exposure and dismantling stage.

Today Chornobyl NPP is in on the final shutdown and preservation stage.

All other nuclear facilities in Ukraine which are under operation (NPPs, storages for spent fuel, research

reactor) have Decommissioning concepts (initial decommissioning plan), which were approved by the

regulatory body.

The above-mentioned aspects are outlined in the presentation.


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Session 1: Decommissioning Strategies and Planning Chair: Mario Dionisi (ISIN, Italy)

The need to develop integrated strategies and plans for nuclear decommissioning has grown in

importance ever since first-generation facilities have reached the end of their operational lifetime and

experience with the dismantling of the facilities and management of the radioactive decommissioning

waste accumulated. It is also one of the major interfaces between nuclear regulators and facility

operators. Regulators must define national strategies for decommissioning and radioactive waste

management with strict requirements for public and workers’ safety, while at the same time respecting

the operators’ more extensive on-the-ground knowledge and without overburdening their economic

resources. It is today understood that decommissioning is a major part of a facility’s lifetime, both in

terms of safety and costs. Planning for decommissioning is therefore now an important part of a

facilities design stage – a requirement that, nowadays, you can find reflected in both IAEA safety

standards as well as in WENRA safety reference levels. At the same time, opinions still evolve, e.g. due

to progress in technological options, a changing public outlook, or changing views of radioactive waste

management.

To illustrate this, Danila Savin from the Russian TSO Scientific and Engineering Centre for Nuclear and

Radiation Safety (SEC NRS) presents the development of planning recommendations by the Russian

supervisory body Rostechnadzor, detailing the steps and options to plan for decommissioning of a

nuclear facility while the facility is still under operation. Participants also discussed the possibilities of

different end-state options for decommissioned facilities and the difficulties in deciding which

operational information will prove important during decommissioning and therefore will have to be

recorded.

Kristina Gillin, Lloyd’s Register’s principal consultant for nuclear decommissioning and waste

management, by reflecting on experiences gained and lessons learned promotes a change of

perspective towards recognising nuclear decommissioning as a sustainability problem and therefore

as part of a bigger picture. This includes understanding decommissioning as a process of site

transformation, also with the aim in mind of enhancing public trust and understanding as well as

reducing the risk of site abandonment.

A changing approach to decommissioning, from a regulator’s point of view, can also be found in the

presentation of Vincent Cloître and Dorothée Conte of France’s ASN. Ongoing delays in several French

decommissioning projects, including legacy sites, and resulting safety concerns led to an understanding

that the currently predominant approach – a case-by-case authorization process – is by itself not

sufficient to deal with these delays. ASN thus asked the three major French operators to describe their

waste management and facility fleet decommissioning strategies and is in the process of assessing

them.

For ENISS, the European Nuclear Installations Safety Standards Initiative, Alain Ensuque presented the

views on applying a graded approach to decommissioning from the licensees‘ perspective. Aiming for

a realistic balance between investments for safety and the resulting safety improvements, ENISS

positions aim therefore to consider risk as well as cost-benefit analyses and the concept of reasonable

practicability.

The subsequent panel, concluding the session, dealt with questions how changes in approach and

perspective could affect the national programmes of EU member states according to Directive

2011/70/Euratom. A possible problem seen by operators was the availability of supplies and services

in an ever more globalized market and delays arising because of possible shortages; discussed was also

the role regulators could play, e.g. in assessing the qualification of suppliers.


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I.

Development of Rostechnadzor recommendations for planning of decommissioning

during operation of nuclear facilities Danila Savin (SEC NRS)

The slides of this presentation can be found in the full version of the Proceedings.


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II.

The need for a sustainable decommissioning paradigm Kristina Gillin (Lloyd’s Register)

Given the age distribution of the world’s nuclear fleet, a large increase

is anticipated in the number of reactors that will be shut down and

require decommissioning. It is therefore more important than ever to

reflect on the experiences gained to date and incorporate lessons

learned into future decommissioning-related endeavours. In doing so it

is vital to consider not only key aspects – such as technical, regulatory,

organizational or financial – but also the paradigm for nuclear back-end

management as a whole.

When stepping back and reflecting on the current paradigm, one clear

pattern emerges: Over the long term, things rarely go as planned. In

particular when it comes to plans for implementing disposal solutions

for spent fuel or radioactive waste. Although the underlying causes may

be interesting to reflect upon, for purposes of a paradigm-level lessons

learned they are hardly relevant. Instead, what is important to acknowledge is the fact that well-

meaning, ambitious plans for nuclear back-end management have a high probability of becoming

significantly delayed or cancelled.

As there is no indication that this reality will change any time soon, the current paradigm is clearly

unsustainable. And with increasing amounts of spent fuel and radioactive waste being stored

indefinitely, the risk that some sites will become abandoned prior to release from regulatory control

cannot be ruled out. Especially given the speed of change and associated risk of instability in society at

large.

This raises the question of responsibility for mitigating the risk that radiological inventories will be left

in a state that poses safety risks if a site becomes abandoned. Regulatory regimes generally require

plans to be in place for both decommissioning and waste management. But when it is known that

those plans have a high probability of not coming to fruition, at least not without major delays, is the

regulator not responsible for enhancing the requirements? If so, what would such enhancements look

like?

By recognizing that decommissioning is part of a bigger picture – the shutting down of an industrial

facility surrounded by communities that will be impacted one way or another – it becomes clear that

nuclear back-end management needs to be approached as a sustainability problem, as a complement

to resolving the technical challenges that lie ahead. The benefits of ensuring that nuclear

decommissioning and waste management are founded on sustainability principles are tremendous:

increased trust, less waste, lower costs and shorter timeline between productive uses on a site. As

well, reduced risk of major delays or dead ends – in turn, reducing the risk that nuclear sites will

become abandoned before long-term safety has been assured.


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III.

Waste management and decommissioning strategies Vincent Cloître, Dorothée Conte (ASN, France)

For the last ten years, the French nuclear safety

authority (ASN) has been confronted with

many postponements of dismantling by the

three major French operators, CEA, EDF and

Orano, whereas they had initially committed to

implement immediate dismantling. A lot of

decommissioning operations and a lot of

retrieval and packaging operations of these

licensees are significantly behind schedule.

Moreover, EDF wants to change its six Gas-

Cooled Reactors (GCR) decommissioning

strategy and postpone the end of their

decommissioning of several decades. For the

40 CEA installations under decommissioning (research reactors, laboratories, reprocessing plants,

etc.), the forecast duration of the decommissioning and legacy waste retrieval operations has been

very significantly increased, several decades for most of them. Decommissioning the old installations

is also a major challenge for Orano, which has to manage several large-scale decommissioning projects

(UP2-400 facility at La Hague, Eurodif Production plant, etc.), with some retrieval and packaging

operations subject to major delays.

These operations affect old or legacy installations, which were built in the 50’s or in the 60’s, which do

not comply with recent safety standards and still contain an important source term. For this reason,

these delays raise major safety concerns. They also lead to leaving the burden of managing

decommissioning and waste to future generation. ASN came to the conclusion that only assessing the

installations decommissioning files, giving the authorizations and supervising them was not enough to

evaluate and control the licensees’ ability to move forward efficiently with their decommissioning

programmes, to comply with the decommissioning schedules and to reduce rapidly the risks in their

installations. In other words, ASN concluded that a case by case authorization process is not enough,

and that a strategic overview was necessary.

ASN thus asked each of the three licensees to submit a file describing their waste management and

decommissioning strategy for their facilities fleet. The goal is to enhance the ASN appropriation of

these strategies and to evaluate the programmes priorities, according to safety, radiation protection

and environmental protection criteria. The evaluation also takes into account the adequacy of the

licensees’ organization, their human, material and financial resources, to carry out their

decommissioning programmes, and the consistency of the decommissioning strategy with the

availability of transport packages, waste storage and packaging facilities.

EDF, CEA and Orano submitted their decommissioning strategy files recently. For the Orano and the

CEA files, ASN assessed it with ASND (Defence Nuclear Safety Authority). ASN is working on its

conclusions on the three files and aims to publish its position by the end of the year 2019.


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IV.

Graded approach of regulation for decommissioning – Considerations on the concepts:

risk informed, cost benefit analysis and reasonably practicable Alain Ensuque (ENISS)

Context

As more and more nuclear power plants are reaching their end of life,

the number of reactors entering the decommissioning phase will

increase dramatically in the near future. The European licensee-

operators, within the ENISS organisation, are concerned about

delivering the related decommissioning programmes safely and

effectively.

Following the design, construction and operation of a nuclear facility,

the decommissioning, up to the delicensing, presents a risk profile

significantly different from the previous stages of the lifecycle. As

parts of the installation are removed, dismantled and

decontaminated, the nuclear and radiological risks are generally

reducing, notably following defuelling. However, during this phase, for some specific operations, the

radiological risk may, on the contrary, increase. Also, during decommissioning, the relative importance

of industrial safety risk may become critical.

ENISS views on the benefits of a graded approach applied to Decommissioning

Over the past few years, ENISS has conducted a thorough reflection on the implementation of a graded

approach to the activities carried out on a nuclear facility. This thinking was guided by key principles:

• Investment in Nuclear Safety should provide significant safety improvements;

• Investment required in providing risk reduction measures should be commensurate with the

safety benefit that will be obtained as a result of their implementation;

• Industry needs accepted methods to make the balance between investment for safety and

safety improvement.

Three concepts have been particularly considered with the objectives of proposing clear definitions

and understanding, as well as goals and criteria for application:

➢ Risk informed

➢ Cost benefit analysis

➢ Reasonably practicable

The application of these concepts and the associated benefits in the area of decommissioning are

illustrated through different typical situations or operations.

Conclusion

ENISS is keen to share and discuss views on these concepts with regulators and other operators to

contribute to an unambiguous understanding and develop processes and methodologies enabling a

safe and effective decommissioning of nuclear facilities.


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Session 2: Regulatory Experience Chair: Stefan Theis (Head of Predisposal Department, ENSI, Switzerland; Chair of WENRA WGWD)

Decommissioning of a nuclear facility not only changes the work of the site’s operator. The regulatory

body, responsible for reviewing license applications and site supervision, will have to adapt to the

change in activities, in the facility itself and in the radiological and conventional work safety risks

included. Operators and regulators will have to find a way to discuss and agree their needs without

compromising safety or hindering efficient implementation of the decommissioning plans. In this

session, examples and experiences from different countries are presented to illustrate the different

approaches taken by different countries to deal with changing interplay between operators and

regulators.

From the competent German authority for the Land of Baden-Württemberg, Theo Neuffer reports

about the challenges for the regulatory body when an NPP enters its decommissioning stage and

Germany’s approach to approving decommissioning activities. The importance of ongoing on-site

inspections is demonstrated by a comparison of dose rates to the operational stage, with little

differences to individual doses even though the overall activity of the facility decreases progressively.

Phil Hallington of Sellafield, Ltd discusses the challenges of managing a complex legacy site and the

recent changes operators, regulators and stakeholders have agreed. This includes the development of

a risk management framework and implementation of more efficient engagement mechanisms.

Fabrizio Trenta of Italy’s national regulatory authority ISIN describes the role of the regulator in a

nuclear environment that is marked by Italy’s decision to close most of the nuclear installations and

abandon far-reaching plans in the wake of the 1986 Chernobyl accident. The duties and functions of

ISIN within Italy’s decommissioning strategy are presented as well as the cooperation with SOGIN, the

1999 established operator for the decommissioning of nuclear installations and waste management.

The regulator and its role in the Swedish system is presented by Martin Amft of the Swedish Radiation

Safety Authority SSM. The approval and authorization processes for decommissioning work in Sweden

is explicated and experiences are discussed, as well as the planned approaches for coming

decommissioning activities.

In the case of the shutdown and planned decommissioning of Swiss Mühleberg NPP, Klaus Germerdonk

for ENSI presented the plans and their regulatory implementation. The regulatory requirements of the

operator are sketched out along with ENSI’s work in review, authorization and supervision to convey

how the regulator approaches the project.

The concluding panel discussed questions of furthering public trust and ensuring the independence of

regulators in the Sellafield example; the foundation of all, as Phil Hallington explained, was

transparency. Crucial is also the public understanding that there is no alternative to decommissioning

and dismantling. While regulators are responsible for supervising nuclear safety and conduct

inspections to do so, inspections for conventional workplace safety and especially for cyber-security

are either done by dedicated departments within the authorities or by different authorities altogether,

as a quick panel survey found. Distinct approaches to licensing decommissioning, in particular for the

transformation between the operational and decommissioning phase of facilities were discussed.

While approaches between countries do differ, all panellists stressed the importance to ensure clear

transitions between licenses.


22

I.

Inspection practice for NPP in decommissioning Theo Neuffer (Ministry of the Environment, Climate Protection and the Energy Sector Baden-

Württemberg, Germany)

The supervision of a nuclear facility in decommissioning can be

divided more or less in three areas. First, there is the supervision of

the operation of the residual systems, then there is the supervision

of dismantling activities including also waste treatment, storage and

the clearance processes and finally in most cases the supervision of

the transformation process of the operator. The competent

regulatory body performs on-site inspections to all of these areas.

Since the dismantling activities differ strongly from the ones in

power operation not only the authorized party but the regulatory

body as well has to adapt. At least with the removal of the nuclear

spent fuel (NSF) the relevant protection goals are reduced to limit

the radiation levels of the workers, environment and the public and the safe enclosure of radiation.

The number of safety relevant systems is reduced strongly as well as linked in-service and maintenance

activities, which have been of special interest for the regulatory body during power operation.

Furthermore, the scheduled annual outage and all fuel handling vanishes.

However, the evaluation of operator data concerning radiation dose levels of workers show clearly,

that there are still topics in focus for the competent regulatory body. Especially at the beginning of

dismantling activities (depending on the dismantling-strategy of the authorized party) there are dose

relevant activities like dismantling of core equipment, core internals or components of the primary

circuit. The evaluation of operator data shows, that the average individual dose during

decommissioning is on equivalent levels compared to power operation. The difficulty for the

regulatory body comes with the fact, that dismantling activities are not that fixed and early scheduled

as e.g. the annual outage or cask handling activities of NSF. Hence, a permanent information flow has

to be guaranteed to schedule on-site inspections of the regulatory body.

To cope with this necessity, the regulatory body in Baden-Württemberg established an allowance-

process that is regulated in the decommissioning license. This allowance process is oriented on the

modification process and states, that decommissioning steps need to be reviewed and finally allowed

by the competent regulatory body before starting any actions. Therefore, the operator has to prepare

reports, which describe the planned dismantling activities and all measures that come along with it.

The regulatory body and its technical support organization review these reports, and finally the RB

approves the reports. Alongside this process, the regulatory body performs on-site inspections on a

regular basis.


23

II.

Enabling Regulation – The Operator’s View Phil Hallington (Head of Policy, Sellafield Ltd)

This Presentation will briefly cover the history of Sellafield and the

background to the current Legacy management challenges on the

Site. The basis for safety justifications will be addressed in the context

of a cumulative risk profile for this complex Site. A Risk management

Framework has been developed in conjunction with Regulators and

key stakeholders to guide priorities and investment decisions. Specific

examples of the benefits to hazard and risk reduction, from adopting

Enabling Regulation will be given. A more effective engagement

mechanism between operators and regulators has been implemented

in recent years, which preserves the Enforcement actions and powers

of Regulators, whilst encouraging sustainable progress with hazard

and risk reduction on a complex Site. Practical experience of this way

of working will be shared.


24

III.

Decommissioning authorization process and controls in Italy Fabrizio Trenta (ISIN, Italy)

In 1964, Italy was the third nuclear country in the world for installed

power behind USA and UK. In 1986 a wide national nuclear

programme was under development with 20 NPPs foreseen. In the

aftermath of the Chernobyl accident, the National program was

cancelled and the nuclear installations, 4 NPPs (Caorso, Latina,

Garigliano, Trino) and 5 Fuel cycle facilities (Eurex, FN, Itrec, OPEC,

Plutonio) were closed and only research reactors were maintained in

operation.

In the mid-nineties the Legislative Decree n. 230/1995 established

the process for the decommissioning authorization until the final

stage.

All nuclear installations were maintained in safe condition until the establishment in 1999 of the

national operator Sogin appointed for the decommissioning of the nuclear installations and for the

management of the waste deriving from the nuclear cycle. In 2001, the Government decided to change

the decommissioning strategy from safe storage to a single step decommissioning of all nuclear

installations and in 2012 the decommissioning authorizations were granted for Trino and Garigliano

NPPs and in 2014 for Caorso NPP. The decommissioning authorization for Latina NPP is foreseen by

June 2020.

According to the plan of the national implementer decommissioning activities are expected to be

concluded in 2035.

The spent fuel was sent abroad for reprocessing and a small amount remains to be shipped for

reprocessing in France.

In 2014, with the transposition of the Directive 70/2011/EURATOM, Legislative Decree n. 45,

established ISIN (National Inspectorate for Nuclear Safety and Radiation Protection) the new national

regulatory authority responsible, at national level, for nuclear safety and radiation protection,

completely independent from any other political and promotional body.

Among the activities that ISIN is required to perform, part of the duties and functions assigned by law

are: technical review and assessment on the documents submitted during authorization processes,

surveillance performed through on site controls and inspections on decommissioning activities,

radioactive waste management, transports, physical protection countermeasures, clearance activities

of materials, effluents discharges, radiation protection of workers, people and environment.

The law establishes, as final stage for decommissioning, the release of the sites without radiological

constrains: at all NPPs sites decommissioning activities are ongoing and control activities will be

showed during presentation.

Clearance of materials represents a focal point for the minimization of radioactive waste as well as the

availability of a national repository represents a primary requirement for the closure of the nuclear

cycle: the concept design for the national repository foresees a near surface disposal facility for

LLW/ILW and an facility dedicated to the long term storage of ILW/HLW, including spent fuel not

reprocessed.


25

IV.

Authorization for and regulatory control of decommissioning in Sweden Martin Amft, Christoffer Forss (SSM, Sweden)

In 1972, Sweden’s first light water nuclear power reactor, Oskarshamn unit

1 (BWR), started its commercial operation. In the following years, 11 more

nuclear power reactors were commissioned at the sites Barsebäck (units

1–2, BWR), Forsmark (units 1–3, BWR), Oskarshamn (units 2–3, BWR), and

Ringhals (unit 1, BWR; units 2–4, PWR). The two units at the Barsebäck site

were permanently shut down in 1999 and 2005, respectively, and have

been in care and maintenance since then. The two oldest units at the

Oskarshamn site were permanently shut down in 2016 and 2017,

respectively. The two oldest units at the Ringhals site are scheduled to be

permanently shut down by the end of 2019 and 2020, respectively.

Additionally, there is the Ågesta PHWR, which has been in long-term care

and maintenance since the mid-1970’s.

Directly after permanent shut down, the spent nuclear fuel, the control rods, and the core

instrumentation are moved from the reactor to the nuclear fuel pool and within 18 – 24 months

transported to the Central Interim Storage Facility for Spent Nuclear Fuel, Clab, operated by Swedish

Nuclear Fuel and Waste Management Company (SKB). Additionally, certain other specified preparatory

activities are allowed to commence before the authorizations for decommissioning have been granted.

In the presentation, the authorizations for decommissioning according to the Act (1984:3) on Nuclear

Activities, the Environmental Code (1998:808), and regulations issued by the Swedish Radiation Safety

Authority (SSM) will be described. In addition to these authorizations, the licensee has to describe the

planned dismantling and demolition activities in greater detail in so-called work packages. Typically,

the dismantling and demolition activities for a nuclear power reactor are described as 10–12 work

packages. SSM has to be notified about these work packages in advance. A formal approval of the work

packages by SSM is not required though.

Although there was essentially a comprehensive regulatory system for decommissioning of nuclear

facilities in place, certain adaptations and completions to the requirements have recently been made

in order to facilitate for the operators to prepare their applications for decommissioning and

supporting documents. SSM achieved this by issuing additional licencing conditions for the seven units

which are permanently shut down or which will be shut down in the near future.

During 2016–2018, SSM authorized the segmentation of the reactor internals of Barsebäck units 1–2

and Oskarshamn unit 2. Formally, these work packages were conducted during care and maintenance

operation. The authorization processes and SSM’s experiences from the regulatory control of these

dismantling activities will be discussed in the presentation.

In December 2018 and April 2019, respectively, SSM authorized the (large scale) dismantling and

demolition of Oskarshamn units 1–2. SSM’s experiences from the review of these applications and

supporting documents will be discussed.

Finally, SSM’s planned approach for the regulatory control of the coming dismantling and demolition

activities, which will take place at seven units in parallel, will be described.


26

V.

Licensing Procedure and Inspection Fields in Decommissioning of Swiss NPP Klaus Germerdonk (ENSI, Switzerland)

In late 2013, BKW Energy Ltd announced that Mühleberg

will be decommissioned by the end of 2019. The single 373

MWe boiling water reactor began operating in 1972. It will

be the first Swiss NPP to be decommissioned.

On 18 December 2015, BKW submitted the application

documents to decommission its NPP (the final

decommissioning plan) to the Federal Department of the

Environment, Transport, Energy and Communication

(DETEC). The application comprises the main report

detailing the decommissioning project’s conceptual

framework and three sub-reports: accident analyses and

emergency protection measures; the environmental

impact report and the nuclear security report.

The requirements for the final decommissioning plan are described in the Nuclear Energy Act, the

Nuclear Energy Ordinance and in ENSI’s Technical Guideline G17. The Decommissioning Guideline

ENSI-G17 is in accordance with the WENRA Safety Reference Levels and the respective IAEA Safety

Standards on decommissioning.

The BKW application documents were reviewed by the relevant authorities such as ENSI. Based on the

authorities’ advisory opinions, DETEC issued the decommissioning order regulating the

decommissioning process in June 2018 – more than one year before final shutdown. No objections to

the order were made to the Federal Administrative Court. The decommissioning order is legally

binding.

Immediately after final cease of nuclear power production on 20 December 2019, BKW Energy Ltd

plans to start some preparatory activities still under the operating license and the conditions of the

decommissioning order. An approval of ENSI for all the steps is required.

For the establishment of the technical post-operation an independent, redundant spent fuel cooling

system will be installed. Preparatory measures include the removal of components in the turbine hall

and the installation of material treatment facilities (cutting, decontamination and packaging).

To reach the final shut down status all necessary technical and organizational measures for the

establishment of the technical post-operation have to be applied and approved. Spent fuel has to be

transferred from the RPV into the spent fuel pool and updated technical specifications and regulations

are implemented. Subsequently, the operating license expires.

According to current planning, the decommissioning project is to be carried out in two phases. During

phase 1, in particular the dismantling of the RPV-internals and systems of the reactor building takes

place as well the removal of the spent fuel from the site.

ENSI will establish a specific on-site inspections program for the decommissioning work carried out by

BKW. Topics already identified are related to nuclear safety and security, staffing & organization, waste

management, dismantling and radiation protection. Relevant findings will be considered for the

oversight activities of ENSI and the overriding aspects related to decommissioning license

requirements.


27

Session 3: Limits of Harmonization and Specific Approaches Chair: Simon Morgan (ONR, United Kingdom)

When countries developed their national regulations for nuclear safety, they could refer to the then

existing IAEA safety standards, but usually did so independently and as they saw fit. One of the main

reasons for WENRA to concern itself about harmonization of national nuclear regulations was to

support its member states to openly discuss their regulatory frameworks and experiences therewith

and to deduct sets of safety requirements that shall serve as a standard to measure the national

regulations against – thereby providing assistance to newcomers to the nuclear field as well as holding

the member states accountable for bringing their national regulations up to par. Nonetheless, many

countries have built regulatory systems that aren’t as easy subjects to harmonization as others are.

Other countries allow for even different approaches to decommissioning.

In the first talk of the session, Stefan Theis explained the WENRA approach of benchmarking national

regulations against WENRA safety reference levels and the limits this harmonization: what about

countries with only a single facility to regulate? What about countries issuing licensing guides that

don’t really fit within the WENRA’s understanding of general applicable regulations but may do their

job just as well?

Holtec’s Corey DeWitt presents an American market approach to decommissioning. In this approach,

Holtec as a dedicated decommissioning licensee acquires ownership of a decommissioning site include

the license, site properties, assets and liabilities, nuclear fuel, and existing organizations and trust

funds set up for decommissioning. By assuming full economic responsibilities and by combining

experiences gained in the decommissioning of several projects, Holtec tries to implement more

efficient and economically viable ways of decommissioning than single-facility operators would be able

to. As was made clear in the subsequent panel discussion, this requires the availability of sufficient

funding, in US cases in the form of trust funds; otherwise the transfer of the site and decommissioning

has to be postponed.

Ulrich Scholl of Kerntechnische Entsorgung Karlsruhe (KTE) gives a progress report on the

decommissioning of the MZFR multi-purpose research reactor at the Karlsruhe Institute of Technology

which is under decommissioning since 1987 and KTE’s experiences with the dismantling of the plant

and the cooperation with the supervising competent authorities.

A novel approach to digital knowledge management in decommissioning promises Joaquin Toubes

Tova of Tecnatom. Addressing the critical need of preserving knowledge about a facility’s design and

intricacies while most of the engineers of the design and operational stage will no longer be around

during the decommissioning of the facility, Tecnatom develops their own methods, using up-to-date

digital methods and the findings of contemporary neuroscience to capture and pass on tacit knowledge

about the facilities and to improve training efficiency.

Discussion in the panel centred around questions of how to navigate differences in understanding of

regulatory requirements between regulators, licensees and stakeholders and the role organisations

like WENRA and ENISS can play to facilitate a shared understanding.


28

I.

Harmonization challenges during WGWD benchmarking Stefan Theis (Head of Predisposal Department, ENSI, Switzerland; Chair of WENRA WGWD)

According to the WENRA policy statement WENRA countries commit

themselves to implement in their regulatory practice a

comprehensive set of safety reference levels (SRLs) which is

understood as the agreed minimum level of safety requirements

which should be fulfilled by licensees in any WENRA country. WENRA

countries are expected to implement these SRLs not on a case by case

basis, e.g. as individual license conditions, but in the generally

applicable parts of their regulatory systems, such as act, ordinance or

mandatory regulatory guide.

Member states are requested to demonstrate the SRL-

implementation in a self-assessment which is later on benchmarked

in a panel session or sub-group-session of the corresponding WENRA working group. Identified needs

for improvement are listed in a national action plan and corrective actions presented to the WGWD

later on.

There are three possible benchmarking results:

A: full compliance, no action required; B: justified deviation, no action required and C: deviation, action required. Whereas results A and C seem to be straightforward, B leaves room for interpretations. Which type of

deviation is justified? Which ones are unjustified?

General considerations of the problem are developed in the presentation including several examples

from the exercises of the WGWD.


29

II.

Site decommissioning by dedicated decommissioning licensee: a US approach Corey DeWitt (Holtec)



30

III.

Decommissioning of the MZFR Ulrich Scholl (KTE)

The Multi-Purpose Research Reactor (German:

Mehrzweckforschungsreaktor, MZFR) located at the

Karlsruhe Institute of Technology (KIT), former Karlsruhe

Research Centre, was a pressurized heavy water reactor. It

was built between 1961 and 1965 and under operation

from 1965 until 1984. The main tasks during operation of

the Multi-Purpose Research Reactor were tests of fuel

elements, material development, training of staff,

electricity production and district heating of the Karlsruhe

research centre. The plant was shut down in 1984 and is

under decommissioning since 1987. It was decided to

dismantle the plant completely and to recultivate its site

(“green field”). Therefore, eight decommissioning licences

were applied for and regulators granted all.

The decommissioning project is currently in last phase of the eighth decommissioning licence. The

reactor internals, the reactor pressure vessel an all former operating systems were dismantled. If

necessary, substitution measures were taken. For example, the old ventilation system was replaced by

decentralised ventilation systems. It was already possible to release some buildings from the Atomic

Energy Act and to tear them down conventionally.

Currently, the focus of the dismantling works is to remove the remaining contaminations. These

contaminations are located inside the auxiliary buildings, the reactor building and the reactor

intermediate building. The most frequent kind of the contamination is Tritium. These decontamination

works require extensive dismantling of reinforced concrete structures. Therefore, it is necessary to

calculate statics for the remaining parts of the building and the replacement measures. For almost

every dismantling of the reinforced concrete structures, we had to apply for an advice of amendment.

The presentation will give a summary over decommissioning steps that are already completed. A more

detailed view on necessary specific approaches during the last decommissioning step follows. The

presentation will conclude with a brief outlook.


31

IV.

Digitalization for Knowledge Management in Decommissioning Joaquin Toubes Tova (Tecnatom)

The amount of information that current organizations need to

manage is huge. Where to store it, how to classify it and

especially, how to distribute it, is usually an issue for managers,

human resources and training departments.

Furthermore, the way of learning has completely changed, as new

generations learn using technology. The new studies based on

neuroscience show the relationship between emotions, learning

and memory. It is demonstrated that knowledge is acquired easily

by doing rather than memorizing.

SOUL is a concept of Knowledge Management developed by

Tecnatom. SOUL takes advantage of digital transformation,

expert knowledge and social collaboration to transfer knowledge

through the organization and to external stakeholders.

In SOUL, the learning model is now centered on the trainee instead of the instructor. The activities are

customized and engaging for the trainees. The training is oriented to performance improvement. The

learning process is open and collaborative in order to promote social learning.

The design, operation and decommissioning of nuclear power plants usually embraces more than two

or three generations of engineers. The ones present during design will probably not be involved in the

operation and these will normally not all be involved in the decommissioning phase either.

Moreover, decommissioning is a critical area for the application of knowledge management systems,

as uncertainty is many times encountered and knowledge is generated along the process.

During the year Tecnatom has developed a pilot program for the application of SOUL to

decommissioning, developing a methodology to capture tacit knowledge and avoid losing it during

generational change, promoting multi-skilled professionals and improving training efficiency.

Tecnatom has applied the methodology to a real-case scenario related to the management of

radioactive waste. Operational experiences have been captured and digitalized and will be essential

for future decommissioning projects. SOUL allows for the use of advanced digital technologies such as

3D simulation, virtual reality and other software developed specifically by Tecnatom for radioactive

waste management and improving decommissioning operations.


32


33

Session 4: Transition from Operation to Decommissioning Chair: Bengt Hedberg (SSM, Sweden)

Ending the operational life of a nuclear facility and entering into the decommissioning stage is a crucial

point for the safe, efficient and successful conclusion to a facility’s existence. Both regulators and

operators have to plan carefully to be able to find answer for the question posed by the occasion.

The first talk to shine some light on these questions is presented by Jim Kershaw of EDF Energy. In the

next ten years all seven Advanced Gas Reactors operator by EDF Energy will have to be closed, a

challenge EDF Energy has begun to tackle by commencing the planning for decommissioning ahead of

the first closure. The presentation details the underling strategy, goals and objectives as well as the

steps to implement them.

Saulius Stravinskas from VATESI, the State Nuclear Power Safety Inspectorate of Lithuania, describes

the authority’s regulatory work during the transition from operation to decommissioning of Ignalina

NPP and shows the progress which has been made in dismantling and decontaminating the facility. At

the same time, the infrastructure for the subsequent radioactive waste management in Ignalina is

developed.

In the Slovak Republic, legislative efforts are underway to clear up yet unaddressed, more complex

issues following the transfer of responsibility for decommissioning to a state organization authorized

by the Ministry of Economy. Miroslav Drahos from UJD, the Nuclear Regulatory Authority of the Slovak

Republic, presents a look back to how the transition period was understood in the past, and a look

forward to how the concept of transitioning now implies new requirements like the transfer of

installations and information from the former operator to the new organization and the cooperative

preparation of the final decommissioning plan.

A talk prepared by ISIN’s Mario Dionisi but ultimately given by Martin Brandauer from NEA summarizes

the topics and results of the 2018 international workshop on regulation of decommissioning –

organized by the Working Party on Decommissioning and Dismantling (WPDD) and the Radioactive

Waste Management Committee Regulators’ Forum (RF) within OECD/NEA. The workshop’s key

findings were presented.

The concluding panel discussions centred for a while on the end point of the transition and the

beginning of the actual decommissioning phase: does the transition end when the facility is free of

nuclear fuel or once activities at the site are performed under a dedicated decommissioning license.

While approaches differ between countries, all panellist could agree that these differences were of

minor importance as long as it was ensured that there was a clear and valid license at all times during

the process. With regards to the AGR decommissioning by EDF Energy, disposal options for the

graphite core were asked about; EDF Energy prepares for a period of SAFSTOR for the core which will

be reviewed by the regulator up to a point where a disposal option has been found. International

initiatives are researching options and facilitating exchange between experts, already. The panel ended

on a discussion about financial provision for decommissioning which is handled differently by almost

every country, but ways will have to be found to compare and assess the adequacy of financing.


34

I.

EDF Energy Planning for Decommissioning during Operation Jim Kershaw (EDF Energy)

Context

EDF Energy operates a fleet of 7 Advance Gas Reactors and 1

Pressurised Water Reactor. The Advanced Gas Reactors (AGRs) will

start to close in 2023, with all closed by 2030. The pressurised water

reactor at Sizewell B is scheduled to close in 2035 or later, and is not

covered by this presentation.

As a long-term nuclear operator in the United Kingdom, EDF Energy

is committed to ensuring that it delivers a safe, timely and cost-

effective decommissioning and associated waste management.

Planning for decommissioning has already commenced ahead of the

first closure, and the presentation will share EDF Energy’s activities

with the WENRA workshop.

Presentation

The presentation to the WENRA workshop will set the context of the EDF Energy decommissioning

programme. It covers the following topics:

• An overview of the AGR decommissioning strategy

• The responsibilities for decommissioning

• The phases of station closures and decommissioning across the EDF Energy fleet.

• The phases of decommissioning for a single EDF Energy station.

• An overview of the discharge route for fuel from site to the waste facilities at Sellafield.

• The strategic goals and objectives of decommissioning.

• Regulatory interactions.

• Closing summary

Conclusion

An overview of the EDF Energy approach to the planning for decommissioning will be presented for

discussion.


35

II.

Lithuanian regulatory policy, challenges and activities during transitional period from

operation to decommissioning of Ignalina NPP

Saulius Stravinskas (VATESI, Lithuania)



36

III.

The Development of Transition Period Requirements in the Slovak Republic Miroslav Drahos (UJD, Slovak Republic)

The transition period has so far been applied twice in the Slovak Republic

and in both cases it was quite unusual. In the case of the A1 NPP1 due to

historical reasons, because the operation termination was relatively

long process itself and several decommissioning activities were carried

out on a case by case basis. In the case of premature shutdown of the

V1 NPP2 transition period was determined by gradual final shutdown of

the reactors and the original operating license validity. Standard

termination activities were performed on the basis of operating

documentation and, in addition, in accordance with “Operation

Termination Concept”, which was not required by the Atomic Act.

Additional transition periods are foreseen for the VVER units currently

in operation.

The current Atomic Act contains basic decommissioning requirements, many of which are also related

to the transition period. Despite prevailing efforts to extend operation of existing units worldwide,

including the Slovak Republic, Nuclear Regulatory Authority considers it important to re-establish and

lay down more detailed requirements for transition period.

A new draft of Atomic Act is currently being prepared. This draft contains a special section dealing

specifically with the operation termination. In defining the transition period requirements, it was

necessary to consider the facts that have occurred since the last update of the Atomic Act.

In particular, it is the ultimate responsibility of the Slovak Republic for decommissioning of nuclear

installations through a State organization authorized by the Ministry of Economy. This new fact implies

additional requirements, such as the establishment of conditions for the handover and takeover of

nuclear installation and associated land between the operator and the State organization. The draft

Act also regulates the cooperation of these organizations in the preparation of the final

decommissioning plan, the transfer of operational information relevant for decommissioning, as well

as cooperation in submitting the decommissioning application.

In this context, it should be noted that the National Nuclear Fund Act has recently abolished the

possibility of using the Fund's resources to cover the costs during the transition period, leaving this

responsibility fully to the operator.

Although some basic aspects of the transition period are quite unambiguous, Slovak legislation will

have to address several complex issues in the near future in order to create a clear legislative

environment for the transition period.

1 HWGCR, shutdown in 1977 after primary coolant system integrity accident, defueled in 1999 2 Two units of VVER, shut down in accordance with the Government Resolution in 2006 and 2008 as a condition for the accession of the Slovak Republic to the European Union


37

IV.

NEA Regulators’ Forum – Outcomes of RF/WPDD Workshop on Regulation of

Decommissioning Mario Dionisi (ISIN, Italy); presented by Martin Brandauer (NEA)

Within the OECD/NEA, the Working Party on Decommissioning and

Dismantling (WPDD) and the Radioactive Waste Management

Committee Regulators' Forum (RF) on 20-21 June 2018 organised an

international workshop on regulation of decommissioning at the OECD

Conference Centre in Boulogne-Billancourt, France.

The workshop was focused on the exchange and sharing of national

experiences and challenges in regulation of decommissioning of nuclear

facilities. The main objectives were to survey the heterogeneity of

challenges, to share national experiences and challenges in regulation of

decommissioning of nuclear installations, to identify best practices and

challenges, and to identify areas and topics for future cooperation.

The workshop addressed a variety of issues from a range of perspectives in four sessions:

• transitioning from operation to decommissioning;

• challenges in ongoing decommissioning activities;

• management of radioactive waste from decommissioning;

• stakeholder engagement and interactions.

Breakout sessions discussed in small groups and contributed to exploring and understanding the

interests and needs of the NEA member countries in the area of regulation of decommissioning.

The workshop has been attended by 61 participants from 19 countries, representing regulatory bodies,

nuclear facility owners and decommissioning implementers, as well as waste management

organisations.

Key issues to be further discussed and investigated in future OECD/NEA initiatives have been identified.

Purpose of the paper is to present these findings.


38


39

Session 5: Final Stages of Decommissioning Chair: Pieter Lietava (SÚJB, Czech Republic)

While there are many ways to decommission a facility and several end states of your site – e.g., if some

of the site’s buildings or infrastructure will be remaining for a future non-nuclear use – there is virtually

always a need for a dedicated regulatory act to release the site and all that may remain on it from

regulatory control. Even if restrictions on further use of the area may be put in place, the site finally

stops being a nuclear facility after that. The site should be clear of any remaining radioactive waste at

this point, its management’s being another issue that needs addressing. The final stages of

decommissioning thus see the facility operator striving to implement the end state of the site as agreed

in the decommissioning plans and licenses; while the regulator’s job is to supervise his efforts and

verify that all obligations have been met. In this session, regulatory experts from Sweden, France and

the United Kingdom describe the regulatory approaches to the end of decommissioning in their

countries and share their experiences.

In the initial talk, Martin Amft of the Swedish Radiation Safety Authority SSM describes the national

approach to the management of radioactive decommissioning waste and the site end state. For waste

above clearance levels a variety of options for reuse in other nuclear facilities or for disposal exist or

are being planned, so the route of radioactive waste management can be tailored for the qualities of

the radioactive waste in question. For the site itself, there’s also the option to release it for unrestricted

or restricted use.

For ASN (in cooperation with the TSO National Institute for Radiological Protection and Nuclear Safety,

IRSN), Coralie Ravier portrays France’s strategy of immediate dismantling and complete clean-out and

release of the facility or site without restrictions. To this end, France’s regulatory framework has been

updated extensively in the past 15 years.

In his concluding talk, Simon Morgan of ONR presents recent regulatory developments in the UK,

including on delicensing nuclear sites, release of radioactive substances, and radioactive waste

management options up to disposal of radioactive waste.

The subsequent panel of the presenters then discussed the range of public involvement in the decision

making about decommissioning and how to define key measures to focus on for optimisation. In the

UK, for example, the regulator weighs all the aspects that need to be taken into account to try to get

a measure for optimisation. In France, the licensee has to deliver a clean-up strategy and provide

laboratory-confirmed proof of its implementation. The release of sites with restrictions on use in place

was questioned with regards to the principle not to shift burdens onto future generations. Panellists

agreed that a restricted site release is mostly important for sites that have critical other functions as

well or are restricted for non-nuclear reasons; furthermore, that it makes no sense to issue restrictions

that cannot be enforced.


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I.

End state requirements for waste and site Henrik Efraimsson, Åsa Zazzi, Martin Amft (SSM, Sweden)

New Swedish regulations on clearance of materials and building

structures and land were issued by SSM in mid-2018. Simultaneously,

Directive 2013/59/Euratom on radiation protection (“the European

BSS”) was implemented in the Swedish legal framework in the form

of the new Swedish radiation protection act and ordinance. The new

radiation protection act contains developed requirements on

clearance in connection with decommissioning of practices involving

ionizing radiation.

The presentation will describe the regulations on clearance, divided

into sections on 1) Clearance of materials, 2) Clearance of building

structures and 3) Clearance of land (often called Site release).

Examples for all three sections will be given on the application of the new regulations (and the earlier,

similar regulations on clearance) on recent and ongoing decommissioning projects, both from nuclear

and non-nuclear activities, in Sweden. Lesson learned so far will be described, as well as plans for

further development of the regulations.


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II.


Coralie Ravier (ASN, France), Patrice François (IRSN)

ASN doctrine regarding decommissioning is based on two major

principles:

− immediate dismantling strategy for all nuclear facilities;

− complete clean-out and release of the facility/site

without any restrictions;

Immediate dismantling strategy:

In accordance with IAEA recommendations, the legal and

regulatory framework in force in France imposes that licensees

of nuclear facilities adopt an immediate dismantling strategy

for all nuclear facilities: decommissioning has to be performed

as soon as the facility is permanently shutdown, without any

waiting period.

To support the immediate dismantling strategy, the legal and regulatory framework has been reviewed

and updated since 2007 to set the decommissioning requirements. Timeframes have been endorsed

to address all aspects of decommissioning in a timely manner including permanent shutdown

notification, the transition period processes, the regulatory review process, the publication of the

decommissioning authorization as well as the planning for decommissioning.

In practice, operators are required to anticipate decommissioning actions from the design stage and

to submit a decommissioning plan subsequently after the notification process for permanent

shutdown. As soon as the decommissioning decree comes into effect, operators have to carry out

decommissioning actions in the shortest delay according to an overall planning and milestones

endorsed in the license conditions.

The aim of this policy is to avoid that the weight of burden of decommissioning regarding technical

and financial aspects on future generations. Moreover, this strategy enables operators to take

advantage from the knowledge and the skills from teams that were working during the operational

phase.

Complete clean-out strategy:

There are no universal clearance levels in France to clear the materials and to release the buildings and

site from regulatory controls during decommissioning. The final end-state of the facility, the clean-out

objectives and the related methodology have to be elaborated and submitted by the operators in the

frame of the decommissioning plan approval.

ASN policy states that the licensee should deploy clean-out processes taking into account the best

scientific and technical knowledge available at the same time and under economically acceptable

conditions, with the aim of achieving an end-state in which all the hazardous and radioactive

substances have been removed from the nuclear facility. This objective allows to come back to the

initial site conditions as they were before the construction of the facility. According to these conditions,

the delicensing of the nuclear facility can be decided by the regulatory body without any institutional

controls.


42

To achieve this objective, the requirements implemented into the legal and regulatory framework set

the conditions to establish at the design stage of the facility a waste zoning survey to identify areas

where radioactive processes are operated and to continuously update and review this survey until the

permanent shutdown of the facility in the perspective of decommissioning.

When the licensee cannot implement fully the ASN policy, in particular for complex decommissioning

projects, a graded approach can be implemented. The objectives are to go as far as reasonably possible

in the clean-out process and the decision to stop the clean-up works must be justified considering

acceptable economic and technical conditions. The decision to release the site from regulatory

controls is then driven putting into balance the remaining radiological conditions and the future and

potential uses of the facility and site. When this approach is not compatible with all uses, some

restrictions can be implemented by the regulatory body.

The complete clean-out strategy complies with the polluter pays principle and aims at removing any

residual risk for future generations.


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III.

Recent developments in the regulation of UK nuclear sites in the final stages of

decommissioning & clean-up Simon Morgan (ONR, United Kingdom)

This paper will cover recent developments in the UK in four separate

but complementary areas which, taken together, are expected to result

in significant improvements to the regulation of the final stages of

decommissioning and clean-up of nuclear sites in the UK:

The UK Government’s proposals to amend nuclear safety and

environmental protection legislation to allow regulators and site

operators to adopt optimised and more sustainable approaches to

decommissioning, radioactive waste management and clean-up on

nuclear sites.

The current development by ONR of regulatory guidance on new

criteria for: (1) ending the period of financial responsibility for nuclear

third-party liability aligned with recent international agreements on exclusions under the Paris

Convention; and (2) revocation of nuclear site licences when all remaining nuclear safety and nuclear

security matters have been fully resolved.

The development and publication of new guidance by the environmental regulators in the UK

establishing numerical and qualitative standards to be met before nuclear sites can then be released

from regulatory control, after clean-up activities involving work with radioactive substances have been

completed.

Initial results from ‘Lead & Learn’ projects carried out by the UK’s Nuclear Decommissioning Authority

(NDA), the site licence company Magnox Ltd and its specialist sub-contractors at nuclear sites in

Trawsfynydd, North Wales and Winfrith in the South West of England. These projects are providing

evidence that the proposed new legislative and regulatory approaches have the potential to result in

significant safety and environmental benefits, and allow more progress in decommissioning and clean-

up across NDA’s estate of nuclear sites.

The paper will explain how the UK Government, nuclear regulators, public bodies and the nuclear site

licensees are working together, in conjunction with extensive stakeholder engagement and public

consultation, to develop an integrated suite of proposals aimed at achieving significant safety,

environmental and decommissioning programme improvements for the nuclear sites in the UK

preparing for and undertaking the final stages of decommissioning and site clean-up.


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Closing Remarks by Stefan Theis (Head of Predisposal Department, ENSI, Switzerland; Chair of WENRA WGWD)

Dear ladies and gentlemen, dear colleagues,

I am glad! Why?

When the idea was launched to have a WENRA decommissioning workshop, I was not convinced at all,

that this would have an added value and could become a success.

Now, after 2 ½ days of intense exchange, a technical tour, a variety of interesting presentations and -

last not least- the lively discussions during the breaks and continuing in the evening: it was really worth

it.

Before elaborating on some personal impressions, I want to thank everybody who made this event

possible; starting with our host the minister of environment and reactor safety, but equally well to all

the authors, who took the chance to let us all benefit from their knowledge and experience. The

organizers will support that in compiling all the presentations and make them available on the WENRA

homepage to all of us and the public.

What key lessons learned will I personally take back home?

• Nuclear decommissioning has become a mature technology application; there is an increasing

number of comprehensive approaches taking into account

− availability of resources,

− interfaces with other facilities at the site,

− critical infrastructure for waste management on the national and international scene,

− training and knowledge management.


45

• Indicators for the “maturity” are amongst others

− an increasing number of young, engaged professionals are attracted,

− an increasing number of enterprises see their chances for revenues,

− major discussions are no longer about individual solutions to technical problems but

on best generic approaches in the framework of individual national situations.

What do they have in common?

Decommissioning is a “waste-driven” process, but: as any process in a free market

environment it is driven by the money available.

• We did not have a single presentation on the funding of decommissioning but a lot of side

discussions on this issue. Obviously, it is very essential that the regulatory system ensures

availability of the necessary financial resources as they are required for the safe dismantling

and decommissioning. This leads me to the role of the regulator which is especially delicate in

a developing and changing industrial field:

• Regulators are expected to set the scene by establishing boundary conditions for acceptable

industrial solutions in guidelines or comparable documents. If we do so in an early phase of

technological evolution, this might narrow the range of possible developments and -after

some years of learning experience- most likely we will have to adapt and improve our

regulations. This could be commented as “being too restrictive” and working with “moving

targets”.

• Taking “risk informed” decisions is requested from us as a novel approach but to do so we

need “risk informed” license applications! That does not mean that our experts will only start

to think about these new ideas, if we receive a license application. In the contrary they will be

available for any in depth technical discussion on chances and risks of new approaches with

the licensees. I personally see at least one problem with this new approach:

Would we in different risk environments take different decisions on the same problem?

According to the new proposals the answer might be yes. Would we, as regulators, be able to

explain this and -even more important- would we consider that as appropriate?

• Eventually regulators will have to change their view on ultimate responsibility for waste

management remaining with the waste producer until the very end of the story. If transfer of

licenses for decommissioning including the ownership of waste and spent nuclear fuel proves

to be an option for successful decommissioning and even speeding up these projects, my

answer is clearly positive: why not, as long as it fits into your legal framework!

• The last message is the most trivial one: Talk to each other! There is no better way to achieve

progress but dialogue: to understand the position and driving forces for decisions of our

counterparts, to open-minded understand new ideas and developments and arrive at critical

but sound judgement on their chances and risks in the best tradition of what we require from

our licensees: continuous learning and improvement.

Concerning the last message this workshop has been a real success; we talked a lot to each other,

officially in the plenum, during the breaks and on many other occasions.

Thanks again to all of you and have a safe trip home!


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Appendix A: Workshop Agenda

Wednesday, 6 November

08:00 – 09:00 Registration, Coffee reception

09:00 – 10:30 Opening Session Chair: Christine Wassilew (BMU, Germany)

WENRA Introduction Mina Golshan (Deputy Chief Inspector, ONR, UK)

International Safety Standards as a basis for the development of national regulations for decommissioning

Nelli Aghajanyan (IAEA)

Regulatory Aspects in Decommissioning: Experiences in Germany and Outlook

Wolfgang Cloosters (Director-General, BMU, Germany)

WENRA WGWD – How the SRLs work

Stefan Theis (Chair of WENRA WGWD)

WENRA WGWD – How SRLs are implemented and how “newcomers” benefit

Tamara Suschko (SNRI, Ukraine)

10:30 – 11:00 Coffee Break

11:00 – 12:30 Session 1: Decommissioning Strategies & Planning

Chair: Mario Dionisi (ISIN, Italy) Rapporteur: Sven Keßen (GRS)

Development of Rostechnadzor recommendations for planning of decommissioning during operation of nuclear facilities

Danila Savin (SEC NRS)

The need for a sustainable decommissioning paradigm

Kristina Gillin (Lloyd’s Register)

Waste management and decommissioning strategies

Vincent Cloître, Dorothée Conte (ASN, France)

Graded approach of regulation for decommissioning – Considerations on the concepts: risk informed, cost benefit analysis and reasonably practicable

Alain Ensuque (ENISS)

Panel discussion All authors of the session

Welcome Address

Svenja Schulze (Federal Minister for the Environment, Nature Conservation and Nuclear Safety, Germany)


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12:30 – 13:30 Lunch break

13:30 – 15:20 Session 2: Regulatory Experience Chair: Stefan Theis (Chair of WENRA WGWD) Rapporteur: Sven Keßen (GRS)

Inspection practice for NPP in decommissioning

Theo Neuffer (UM BW, Germany)

Enabling regulations from the operator’s view

Phil Hallington (Sellafield Ltd)

Decommissioning authorization process and controls in Italy

Fabrizio Trenta (ISIN, Italy)

Authorization for and regulatory control of decommissioning in Sweden

Martin Amft, Christoffer Forss (SSM, Sweden)

Licensing Procedure and Inspection Fields in Decommissioning of Swiss NPP

Klaus Germerdonk (ENSI, Switzerland)


15:20 – 15:50 Coffee break

15:50 – 17:20 Session 3: Limits of Harmonization and Specific Approaches

Chair: Simon Morgan (ONR, UK) Rapporteur: Sven Keßen (GRS)

Harmonization challenges during WGWD benchmarking

Stefan Theis (Chair of WENRA WGWD)

Site decommissioning by dedicated decommissioning licensee: a US approach

Corey DeWitt (Holtec)

Decommissioning of the MZFR Ulrich Scholl (KTE)

Digitalization for Knowledge Management in Decommissioning

Joaquin Toubes Tova (Tecnatom)


17:20 End of day 1


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Thursday, 7 November

08:30 – 09:00 Coffee reception

09:00 – 10:30 Session 4: Transition from Operation to Decommissioning

Chair: Bengt Hedberg (SSM, Sweden) Rapporteur: Sven Keßen (GRS)

EDF Energy Planning for Decommissioning during Operation

Jim Kershaw (EDF Energy)

Lithuanian regulatory policy, challenges and activities during transitional period from operation to decommissioning of Ignalina NPP

Saulius Stravinskas (VATESI, Lithuania)

The Development of Transition Period Requirements in the Slovak Republic

Miroslav Drahos (UJD, Slovak Republic)

NEA Regulators’ Forum – Outcomes of RF/WPDD Workshop on Regulation of Decommissioning

Mario Dionisi (ISIN, Italy); presented by Martin Brandauer (NEA)


10:30 – 11:00 Coffee break

11:00 – 12:30 Session 5: Final Stages of Decommissioning

Chair: Pieter Lietava (SÚJB, Czech Republic) Rapporteur: Sven Keßen (GRS)

End state requirements for waste and site

Henrik Efraimsson, Åsa Zazzi, Martin Amft (SSM, Sweden)


Coralie Ravier (ASN, France), Patrice François (IRSN)

Recent developments in the regulation of UK nuclear sites in the final stages of decommissioning & clean-up

Simon Morgan (ONR, UK)


12:30 Closing Remarks Stefan Theis (Chair of WENRA WGWD)

12:45 End of workshop, departure


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