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© Nov.2016 ANDES Regulations for Decommissioning of Nuclear Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association for Nuclear Decommissioning Study 1 Tadamichi Satoh The Association for Nuclear Decommissioning Study 2016 Sino-Japanese Workshop on NPP Decommissioning Technology November22, 2016 @ Atomic Energy Council 3F

Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

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Page 1: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES

Regulations for Decommissioning of Nuclear Power Plants in Japan

~aiming to achieve the safe, smooth, and reasonable decommissioning~

The Association for Nuclear Decommissioning Study

1

Tadamichi Satoh

The Association for Nuclear Decommissioning Study

2016 Sino-Japanese Workshop on NPP Decommissioning Technology

November22, 2016 @ Atomic Energy Council 3F

Page 2: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES

Potential Risks of Over-Regulation(過剰規制がもたらす弊害)

1. Reduce worker motivation(作業者の意欲を低下させる)

2. Reduce worker focus on real issues(真の問題への作業者の意識を低下させる)

3. May be in conflict with industrial safety(産業安全と矛盾しかねない)

4. Delay the final goal of site release(廃止措置の完了を遅らせる)

5. Provide the wrong message to the stakeholders and public in

particular (利害関係者や特に公衆に誤った情報を与える)

Avoid unnecessary operation-type burdens

(不必要な運転中の規制負荷を避ける)

2

Harmonization of standards and procedures versus

flexibility of approach

From the panel discussion on ”Emerging issues and trends in regulatory practices

during the decommissioning and dismantling of nuclear power plants”

OECD/NEA/WPDD Topical Session 2006

Page 3: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES

Safety consideration

while operation Safety consideration

while decommissioning

- Strict compliance with operation rule and maintenance rule - Control room staffing (24-hours) - Preparedness for Sevier Accident - Extensive inspection of facilities by regulator

【Point】 - Operate reactor safely & SAM - Maintain safety function of facilities (Shutdown system, Core cooling system, Containments) - Safeguard control

【Point】 - Plan and control works safely including industrial safety -Control of radiation & radioactive waste -Confirm final status of the waste and the site to be safe

- Oversight of decommissioning activity

Comparison of Safety consideration

between operation and decommissioning

Protection of - General public health - Workers health

3

Page 4: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES

Changes from Operation to Decommissioning ~Changes of Plant Situation 施設状態の変化~

IAEA TRS/No.420 Transition from Operation to Decommissioning of Nuclear Installation(2004)

Operations 運転中 Decommissioning 廃止措置

Safety management systems based on an operating nuclear facility

原子力施設の運転を対象とした安全管理体系

Safety management systems based on decommissioning tasks

廃止措置作業を対象とした安全管理体系

Focus on functioning of systems 系統の機能に集中

Focus on management of material and radioactivity inventory (e.g. for waste minimization)

物や放射能物量に集中(廃棄物の最少化など)

Reliance on permanent structures for the operating life of the facility

恒久の構造物に依存

Introduction of temporary structures to assist dismantling

仮設構造物の導入

Routine amounts of material shipped off-site

一定量の所外搬出

Larger amounts of materials shipped off-site

多量の所外搬出

Established and developed operating regulations

確立された運転中規制

Change of regulatory focus 規制焦点の変化

4

Page 5: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES

IAEA TRS/No.420 Transition from Operation to Decommissioning of Nuclear Installation(2004)

Operations 運転中 Decommissioning 廃止措置

Predominant nuclear and radiological risk 核的・放射線危険が中心

Reduction of nuclear risk, changed nature of radiological risk, significantly increased industrial risk

核的危険は低減、放射線危険の特質の変化 労働安全上の危険が増大

Working environment well known 作業環境が良く判っている

Working environment unknowns possible

作業環境が判っていない可能性

Low radiation/contamination levels relatively unimportant

低線量、低汚染は管理上重要度が低い

Low radiation/contamination levels important for material clearance

低線量、低汚染もクリアランスの観点で重要

Access to high radiation/contamination areas unlikely or for a short time

高線量、高汚染の場所への立入は稀で短時間

Access to high radiation/contamination areas for extended periods

高線量、高汚染の場所への長時間の立入

Relatively stable isotopic composition 核種組成は比較的一定

Isotopic composition changing with time 時間と共に核種組成が変化

Changes from Operation to Decommissioning ~Changes of Work Condition 作業環境の変化~

5

Page 6: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES

IAEA TRS/No.420 Transition from Operation to Decommissioning of Nuclear Installation(2004)

Operations 運転中 Decommissioning 廃止措置

Production oriented management Objectives 生産指向の運営

Project completion oriented management objectives

事業完遂指向の運営

Permanent employment with routine objectives

定常業務での恒久雇用

Visible end of employment — refocus of the staff’s work objectives

雇用の明確な終了/新たな業務に向けた再意欲

Repetitive activities 反復作業が多い

One-off activities 単発作業が多い

Routine training and refresher training

定例訓練と再訓練

Retraining of staff for new activities and skills or use of specialized contractors

新たな業務、技能の訓練又は専門家の雇用

Routine lines of communication 定常的な対話先

New lines of communication 新たな対話先

Changes from Operation to Decommissioning ~Changes of Human Factor 人的な変化~

6

Page 7: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES

1.Health and safety of workforce

Particular regulatory attention to conventional health and safety (increased potential for fire, explosion, failure of partially dismantled structures, accidents associated with lifting and moving heavy items, etc.)

New working environment that involve a changing work force comprised of temporary, contract staff

Lack of attention to the changing of nature and location of hazards

2.Modification of plant and equipment

Regulatory approval process would be modified for decommissioning machinery and ancillary plant

3.Control of radioactive contamination

The matter of nuclear safety becomes negligible during decommissioning

Focus more on matters concerned with control of contamination and minimization of waste creation

⇒ Minimize impact on workers, the public and the environment

7

Achieving a regulatory balance in decommissioning phase

~ the most important point considered by OECD/NEA/WPDD ~ 1

”Regulating the Decommissioning of Nuclear Facilities” OECD/NEA 2008

Page 8: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES

4.Control of human and organizational issues

New and different management reflecting the need for greater emphasis on project management, i.e. the management of change, quality control, information retention, contract management

(different from operational phase where activities are generally routine and well practiced by

a stable work force)

The management to be flexible and able to respond quickly to new situations ⇒ Vesting the local site management with a range of powers

(various new decommissioning activities may need closer day-to-day control or supervision)

5.Knowledge retention

Availability of information about operational history of the plant

First-hand knowledge of design, construction and operation of the plant

Knowledge of any unrecorded plant modification and any untoward events during operation

8

Achieving a regulatory balance in decommissioning phase

~ the most important point considered by OECD/NEA/WPDD ~ 2

”Regulating the Decommissioning of Nuclear Facilities” OECD/NEA 2008

Page 9: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES

Tokai-1 is the first instance of the decommissioning of a commercial

nuclear power plant in Japan

Mar.1998 Permanent Shutdown (32 years operation)

May 1998 –Mar.2001 Defueling

Jun. 2001 The last shipment of spent fuel

Oct. 2001 Submitted the notification decommissioning plan

Dec. 2001 Commenced decommissioning activities

Dec.2005 Amendment of the “Act on the regulations of nuclear

source material, nuclear fuel material, and reactors”

Mar. 2006 Submitted the application of decommissioning plan

Jun. 2006 Approval of the decommissioning plan

9

Experience of Improvement of Decommissioning Regulations in Japan

Page 10: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES 10

At the beginning of Tokai-1 D project

Existing Regulatory Systems & Practices were applied

That was to basically regulate operating plants

aiming to operate reactor safely and maintain

safety function of facilities.

- 24-Hour sift operator arrangement

- Periodical Facility Inspections by regulator and

utility

- Strict Operational Safety Program (OSP) (保安規定) (approved by regulator)

- Rigid regulatory procedure for modification of

facilities (including temporary facilities )

Regulations were not suitable for decommissioning phase

No clear standard was established for decommissioning regulations

Page 11: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES 11

Moving from Operation to Decommissioning

Safety function appropriate for plant changing condition Final state of wastes

Final state of the site

Add

Remain

Take out

Objects to be regulated are changed at the situation on No reactor operation and no nuclear fuel Arising of many different types of waste Changing of plant condition as decommissioning

progress

Operate reactor safely Maintain safety function of facilities Safeguard control

Radiation control Waste management OSP for necessary facilities

不要

継続

追加

Page 12: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES 12

Key point of the amendment in 2005

Rationalization of regulation for

decommissioning phase

1. Clarification of decommissioning start point

- DP is applied at plant shutdown

- At DP approval, regulations are changed to

decommissioning regulation from operation regulation

2. Exemption of regulation for reactor operation

after DP approval;

- 24-hour sift monitoring

- Annual regulatory inspection by regulator(after defuel)

3.Clarification of DP & OSP description

- describe only key items for safety in

decommissioning phase

Page 13: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES 13

Comparison between former & new regulation

Former regulation

(before Dec.2005)

New regulation

(after Dec.2005)

Decommissioning Plan

(DP) (廃止措置計画)

Notification Too detail description

Approval Only safety items description

Operational Safety Program (OSP)(保安規定)

Approval Too detail description

Approval Only safety items description

Mandatory periodic inspection of facility by regulator

Annual NA

(after defueling)

On site inspection of compliance with OSP by regulator

Quarterly

(~2 weeks)

Less than quarterly

(~1 week)

Safety control Daily patrol Monitoring by shift operator

Weekly patrol

No shift operator

Completion of decommissioning

Final report to regulator Confirmation by regulator

Page 14: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES 14 14

Summarize of Old/Current Decommissioning Regulations

[Flow Chart of Decommissioning Regulations]

Reactor Operation Fuel Removal Facilities Dismantling/Wastes Shipping

Cessation of Operation Completion of Fuel Removal

License

Termination Dismantling

Notification

Old Before

Dec.2005

Decommissioning Phase Operating Phase

D Completion

Report

Current After

Dec.2005 D Planning

Application/

Approval

Operating

Phase Decommissioning Phase

* Less strict regulations during D Phase according to the facilities status

License

Termination

D Completion

Confirmation by

Government

(It is specifically prescribed under Minister Ordinance)

Alteration of

OSP

Alteration of

OSP

(Amend according to D progress)

(Amend according to D progress)

Page 15: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES 15

New Regulations for Operating Plants after the Fukushima Daiichi Accident

New Regulatory Requirements for Light-Water Nuclear Power Plants August 2013 Nuclear Regulation Authority

Page 16: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES

Added requirements to the NRA’s standard review

procedure for Decommissioning Plan in 2015

Any decommissioning works shall not have a negative

effect on safety functions of operating plants in same site

including SAM.

Integrity evaluation for spent fuels in cooling pool in case

of loss of coolant.

16

Page 17: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES 17

Key points for the safe(安全), smooth(順利), and reasonable(合理的) decommissioning

意識転換 Change your Mindset to Decommissioning from Operation

三現主義 :現場、現物、現実

(Sangen shugi) ‘Three Reals Philosophy’

Go and see by yourself and understand the situation

Page 18: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES 18

End of Presentation

Tadamichi Satoh

Secretary-General

The Association for Nuclear Decommissioning Study

Address:

401 Yoshida Bldg., Kudan-kita, chiyoda-ku,

Tokyo 102-0073 Japan

Phone: +81-3-6272-4150

Fax: +81-3-6272-4470

E-mail: [email protected]

URL: http://www.decomiken.org

Page 19: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES 19

Current Decommissioning Regulation in Japan

Reference Source : Presentation of Japan Nuclear Regulation Authority “Safety

Regulations for Decommissioning of Nuclear Power Plants in

Japan and Future Challenges”

NRA-NRC Workshop on Decommissioning of Nuclear Power

Plants, April8, 2015

https://www.nsr.go.jp/data/000104112

Page 20: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES 20

https://www.nsr.go.jp/data/000104112

Page 21: Regulations for Decommissioning of Nuclear Power Plants in … · 2016-11-16 · Power Plants in Japan ~aiming to achieve the safe, smooth, and reasonable decommissioning~ The Association

© Nov.2016 ANDES 21

Under the rules for installing and operating the commercial power reactors,

the following standards have been prescribed for approving a

decommissioning plan.

Spent fuels shall have been taken out from the reactor core.

(Paragraph 1 of Article 119 of the Rules)

Management and transfer of nuclear fuel materials shall be appropriate.

(Paragraph 2 of Article 119 of the Rules)

Management, processing and disposal of nuclear fuel materials and

radioactive waste shall be appropriate.

(Paragraph 3 of Article 119 of the Rules)

Proper protective measures shall be taken against disaster caused by

nuclear fuel materials, contaminated materials and nuclear reactor.

(Paragraph 4 of Article 119 of the Rules)

NRA shall confirm in a safety review that the decommissioning plan applied by

the licensee conforms to the standards mentioned above.

3-3 Requirements for Approval of Decommissioning Plan (1)

https://www.nsr.go.jp/data/000104112

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© Nov.2016 ANDES 22

https://www.nsr.go.jp/data/000104112

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© Nov.2016 ANDES 23

https://www.nsr.go.jp/data/000104112

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© Nov.2016 ANDES 24

3-4 Requirements for Confirming the Completion of Decommissioning

https://www.nsr.go.jp/data/000104112

The rules provide the following standards for confirming the completion of

decommissioning:

That transfer of nuclear fuel material is completed.

(Article 121, Item 1)

That no measures are needed to prevent damage from radiation in regards

to the soil and remaining facilities on the premises of facilities to be

decommissioned.

(Article 121, Item 2)

That management of radioactive wastes is completed.

(Article 121, Item 3)

That transfer of radiation management records to the institution designated

by the Nuclear Regulation Authority is completed.

(Article 121, Item 4)

Based on documents and on-site surveys, the Nuclear Regulation Authority

verifies that the completion of decommissioning reported by the operator

fulfills the above standards.