licensing of waste management facilities · management of different types of radioactive waste and...
TRANSCRIPT
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IAEA International Atomic Energy Agency
name of presenter (e-mail)
training event title
dates
location, host organization, host country
Licensing of waste management facilities
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Contents
• Basic Framework
• Roles and Responsibilities
• Licensing Process
• Documentation
• Follow-up Activities
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Scope
• Licensing of waste management facilities,
applicable not only for
larger facilities but also
for smaller (e.g. storage)
facilities
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Relevant IAEA documents
IAEA Safety Standards
Fundamental
Safety Principles
Safety Fundamentals
f or protec ting people and t he env i ronm ent
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Introduction
Licensing:
• Activities/facilities from very low risk to high potential risk
• Extent of control commensurate with potential magnitude and nature of hazard
• Authorization procedures from notification/registration to multistage
licensing
Construction, operation, decommissioning
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Introduction
Authorisation and Licence(s)
• Siting, design, commissioning, operation, maintenance, shutdown and decommissioning
• Different approached in Member States
Safety Documentation and Evolution
• Safety case (SC)
• Safety assessment (SA)
• Other supporting documents
Siting Design Operation Shutdown Decommissioning
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Established regulatory framework a prerequisite:
• Legal framework
• Governmental infrastructure
• Regulatory body (-ies)
Introduction
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• Laws, regulations, guidance, etc.
• Safety requirements and criteria
• Activities and facilities requiring a license (siting, design, construction, operation, closure of a near surface repository)
• Responsible authorities
• Involvement of stakeholders (e.g. public)
• Licensing procedure
• Procedure for refusal and appeal
• Mechanisms for amendment and withdrawal of a license
Framework for Licensing
Ingredients..
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Roles and responsibilities
• Identification of the parties involved in waste management activities and their responsibilities;
National Radioactive waste system should include:
Government Regulatory Authority
Generators and operators
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Parties
• Applicant
• Regulatory body
• Interested parties (e.g. public, politicians)
Responsible Parties
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• Regulatory body or bodies: Clear allocation of authority (eg radiation protection,
environmental protection)
Coordination and consistency in:
• Documentation required
• Review and approval of safety related documentation
Ultimate licence
Control of compliance with licence conditions after
authorization
Governmental Infrastructure
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Responsibilities
Requirement 23: Authorization of
facilities and activities by the
regulatory body
Authorization by the regulatory body,
including specification of the conditions
necessary for safety, shall be a
prerequisite for all those facilities and
activities that are not either explicitly
exempted or approved by means of a
notification process.
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Responsibilities
For a facility, the stages in the lifetime
usually include:
•site evaluation,
•design,
•construction,
•commissioning,
•operation,
•shutdown and
•decommissioning (or closure).
This includes, as appropriate, the
management of radioactive waste and
the management of spent fuel, and the
remediation of contaminated areas. 13
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Responsibilities
• Any subsequent amendment, renewal, suspension or revocation of the
authorization for a facility or an activity
shall be undertaken in accordance with
a clearly specified and established
procedure.
• The safety assessment may need to be repeated or reaffirmed by the
regulatory body in support of its
decision.
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GSR Part 5. - Requirement 3:
Responsibilities of the regulatory
body: …The regulatory body shall review and assess
the safety case and the environmental impact
assessment for radioactive waste management
facilities and activities, as prepared by the
operator both prior to authorization and
periodically during operation. The regulatory
body shall provide for the issuing, amending,
suspension or revoking of licences, subject to
any necessary conditions. The regulatory body
shall carry out activities to verify that the
operator meets these conditions...
Responsibilities
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Regulatory body:
• Requirements/criteria
• Procedure for review of applications
• Guidance to applicants
• Justify licensing, refusal of granting a license, amendments, withdrawal of a
license
• Provide information to stakeholders
Responsibilities
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Responsibilities
Requirement 24: Demonstration
of safety for the authorization of
facilities and activities
The applicant shall be required to submit
an adequate demonstration of safety in
support of an application for the
authorization of a facility or an activity.
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GSR Part 5. - Requirement 4:
Responsibilities of the operator.
Operators shall be responsible for the safety
of predisposal radioactive waste management
facilities and activities. The operator shall
carry out safety assessment and shall develop
a safety case, and shall ensure that the
necessary activities for siting, design,
construction, commissioning, operation,
shutdown and decommissioning are carried
out in compliance with legal and regulatory
requirements.
Responsibilities
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Applicant:
• Submit complete set of application doc. that
• Demonstrates compliance with safety principles (e.g. optimization, defence in depth, containment and isolation)
• Justifies and demonstrates compliance with safety requirements and criteria (e.g. dose/risk constraints) of the proposed activity/facility (safety assessment and safety case)
• Demonstrates available human and financial resources
• Long-term arrangements (institutional control)
• Consult with the regulatory body
• Consult with other stakeholders (public)
Responsibilities
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Other interested parties • Public
• Part of the licensing process
• Public consultation (e.g. EIA)
• Possible involvement in the review phase
• Parlament/Politicians
• E.g. volunteer of a disposal site
• Some facilities may need parliament endorsement
Responsible Parties
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Licensing Process
Submission
• Documentation according to the legal requirements
• Approval(s) of competent authorities
• Results of consultations (e.g. public)
• Supporting documentation
(e.g. results of peer reviews)
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Supporting documentation
Safety case:
• System description; Safety assessments; Operational limits, controls and conditions; Safety supporting arguments;
Operational Documentation:
• Radioactive waste management program
• Radiation protection program
• Monitoring program
• Management system program
• Record keeping
• Emergency plan
• Physical protection plan
• Training programs
• Outreach programmes;
Justification of resources (human/financial) 22
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Basis for Evaluation
• Legal and regulatory frameworks
• Governmental infrastructure
• Regulatory body
• Technical and safety requirements and criteria
• Clear allocation of responsibilities
• Authorisation procedure, licence application, review criteria, timeframes and parties involved
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Basis for Authorisation (cont.)
RB Other
Competent
Authorities
Public
Government
International Obligations
International Organisations
Member
States
Licensee RB
Laws and Regulations
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Basis for Authorisation (cont.)
A Legal and Regulatory Frameworks
• Laws, regulations, guidance, etc.
• Safety requirements and criteria
• Activities and facilities requiring a licence (siting, design, construction, operation, shut-down, decommissioning)
• Responsible authorities
• Involvement of stakeholders (e.g. public)
• Authorization procedure
• Procedure for refusal and appeal
• Mechanisms for amendment and withdrawal of a licence
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Basis for Authorisation (cont.)
Government Infrastructure
• To define the national policy for the long term management of different types of radioactive waste and spent fuel
• e.g. existing and planned facilities and activities
• To set clearly defined legal, technical and financial responsibilities for organizations to be involved in waste predisposal management activities
• Waste Management Organisations
• Waste Funds
• Decommissoning Funds
• To define the overall process for development, operation, closure and decommissioning of facilities
• Ensure compliance with international obligations
• Joint Convention, etc.
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Basis for Evaluation (cont.)
Regulatory Body:
• Setting safety requirements and criteria
• Authorisation, inspection, review and enforcement
• Defining licensing application documents
All phases of facility lifetime
• Establishing procedure for review of applications
• Provision of guidance to applicants
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• All steps from an application to a final decision
• Parties involved at each stage (e.g. hearings)
• Timeframes for review and final decision
• Regulatory body/applicant interface
Documentation of the Licensing Procedure
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Licensing Procedure
Parties involved • Operator/licence applicant
• Independent reviewers
• Regulators
• Public/other stakeholders
Review steps • Preliminary review (incl. peer review)
• Presentations of comments, request for additional information
• Consideration of the comments and submission of the required information to the regulatory body for evaluation
• Final review and decision on granting a licence 29
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Licensing procedure
Regulatory decision making process
How can the regulatory body decide?
To grant or to refuse the licence.
What is the basis of regulatory decision?
Strong justification and clear reasoning
Well documented decision making process
Documentation to be preserved and archived
Dissemination of information to the relevant competent
authorities
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Basis for Evaluation
Regulatory Body (cont.): • Justification of licensing, refusal or granting a licence,
amendments or withdrawal of a licence
• Provision of information to stakeholders
• Appealing procedure
• Coordination with other competent authorities Security Non-radiological aspects Emergency planning Environmental monitoring, EIA, etc.
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Basis for Evaluation (cont.)
Technical and safety requirements and criteria
- dose limits
- dose constraints
- discharge limits
- clearance levels
- waste classification
- requirements for processing, storage, transport and disposal of waste, etc.
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Basis for Evaluation (cont.)
Technical and safety requirements and criteria (examples)
a. Criteria for clearance of material
• IAEA Guidance from RS-G-1.7
• Effective dose to individuals not more than about 10 µSv/y
• Collective dose < 1 manSv, or an assessment of optimization of protection shows that clearance is the
optimum option
• Naturally occuring RN – 1 Bq/g and 10 Bq/g (K-40)
• Or set by the national authorities
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Basis for Evaluation (cont.)
b. Waste characterization and classification
In accordance with the requirements established and approved by the regulatory body
GSG-1 Safety Guide (IAEA)
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Basis for Evaluation (cont.)
Technical Requirements for Storage of Radioactive Waste
• Waste characterization
• Waste acceptance criteria
• Description of the facility, components, equipment and systems
• Siting and desing, construction, operation, commissioning, shutdown and decommissioning
• Safety documentation (SC):
SA
Radiation protection programme
Environmental monitoring
Security and physical protection plan
Emergency plan
Management system, etc.
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Basis for Evaluation
Parties Involved and their Responsibilities
• Operator/licence applicant (e.g. also TSO)
• Supporting organisations (e.g. (sub)contractors)
• Regulator(s) (e.g. also TSO)
• Independent reviewers (e.g. international - IAEA)
• Public/other stakeholders
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Basis for Evaluation
Authorisation Procedure and Review Steps
• Preliminary review (screening) of licence application
• Detailed review (incl. peer review)
• Possible visit to the site/facility
• Presentations of comments, request for additional information, studies or investigations
• Consideration of the comments and submission of the required information to the regulatory body for evaluation
• Final review and decision on granting a licence
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Basis for Evaluation
Authorisation Application Review Plan • Regulatory body establishes a plan for review and
evaluation • All steps from an application to a final decision
• Define phases, if necessary • Parties involved at each stage (e.g. hearings)
• Timeframes for review and final decision
• Regulatory body/applicant interface
• Overall responsibility for the review and decision, and
their documentation
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Approach to Evaluation
Scope of Authorisation Application
• Siting, design, operation, modification, shutdown or decommissioning
• Activities/facilities from very low hazards/risk to high potential hazards/risk
• Separate authorization of an activity or a general authorisation for more activities
• Extent of control commensurate with potential magnitude and nature of hazards - graded approach
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Graded Approach
Maintenance waste
candidate for clearance
Spent fuel storage
facility
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Approach to Evaluation (cont.)
Scope of Waste Management Activities
i. Waste processing (pretreatment, treatment and conditioning)
ii. Storage of radioactive materials, previously conditioned in containers that are physical barriers to prevent dispersion of radioactive materials
iii. Removal of control and subsequent authorized release (clearance), in compliance with clearance levels approved by the regulatory body
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Approach to Evaluation (cont.)
Regulated Practice
Regulated transfer
to other facility Regulated disposal
Authorised recycling,
reuse and disposal
Clearance
Authorised release and
discharge
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Licensing procedure
Review of application • Regulatory body programme for review and
assessment
• Review of documentation (SC, supporting arguments)
• Internal (independent assessment)
• External (independent expert(s), international peer review)
• Request for additional information
• Request for additional studies and investigations
• On-site inspections
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Procedure (cont.)
• Parties involved: Applicant / operator ;
Regulator(s);
Independent reviewers;
Public / other stakeholders.
• Timeframes:
• For review (incl. peer review) and within that: Presentations of comments, request for additional
information;
Consideration of comments and submission of
additionally required information;
Final review and decision on granting a license. 44
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Procedure (cont.)
• Regulatory body/ applicant interface:
• Licensing programme prior to submission: Schedule the main activities;
Agree the scope and content of the main documents;
Methodology for comment and query tracking;
Agree contact persons.
• Effective incorporation of comments & recommendations;
• Detailed face-to-face discussions may help but these should focus on clarification and should
be kept formal.
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Conduct of Evaluation
The Regulatory Body should be sure
that the description of the facility
includes:
Volumes by types of waste
Physical, chemical, radiological and
biological characteristics of waste
Types of containers that are
planned to be used
Principles and methods used
Acceptance criteria for waste which
will be managed in the storage
facility (for a package and for the
facility in total)
Evaluation
Technical
Aspects
Safety
Aspects
Managerial
Aspects
Technical Aspects
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Conduct of Evaluation (cont.)
Description of the facility, components, equipment and systems:
• Main characteristics of the geographical site of the facility, access routes, basic services (electricity, water, etc.) and waste disposal routes
• Layout of the building, construction materials, materials used in finishing and covering of walls and floors etc.
• Storage capacity by package type or forms of waste
• Systems for package handling, transport and lifting
• Radiation protection and environmental monitoring
• Emergency measures
• Ventilation systems
• Technical support for physical security
Technical Aspects
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Conduct of Evaluation (cont.)
The regulatory body has to be sure that:
• The actual characteristics of waste accepted meet the characteristics taken into account in the development of the safety case.
• The operator knows the waste acceptance criteria in terms of radiological, mechanical, physical, chemical and biological characteristics
• The operator knows the role of the waste acceptance criteria to ensure the safe handling and storage of waste packages in normal and abnormal conditions
• The operator knows how to identify, assess and deal with waste packages that do not meet specifications
Technical Aspects
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Conduct of Evaluation (cont.)
The regulatory body has to implement onsite surveillance, package testing, inspection in order to ensure: • That the waste packages meet the required acceptance
criteria for storage or processing
• Adequacy of the licence application documentation
Technical Aspects
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Conduct of Evaluation (cont.)
The regulatory body should be sure that the operator:
• Carries out, reviews and updates safety assessments and develops the necessary supporting safety cases for siting, design, construction, commissioning, operation, shutdown and decommissioning
• Compliance with legal and regulatory requirements
• Takes into account the interdependences among all steps in the predisposal management of radioactive waste, as well as the impact of the anticipated disposal option
Safety Aspects
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Conduct of Evaluation (cont.)
Safety Assessment and Safety Case
• Preliminary Safety Assessment Report is submitted together with the construction licence application
• Final Safety Assessment Report is submitted with the operation licence application
• Supporting arguments
• Operational limits and conditions
• SA input to the Safety Case together with, e.g.:
Initial decommissioning plan
Reference background surveys, etc.
Safety Aspects
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Use of safety assessment results
Results of safety assessment will be basis for: • waste acceptance criteria • derivation of procedures or equipment required to
minimize doses
• definition of operational limits, conditions and controls (OLCs) to prevent unacceptable exposures and releases during normal operations and prevent accident conditions or to mitigate accident consequences safe operating envelope
• derivation of operational procedures to ensure that operations remain within the OLCs
Safety Aspects
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Conduct of Evaluation (cont.)
Other elements of SC, e.g. emergency planning:
• Planning for emergency response is based on the results of a safety analysis
• Emergency situations
• Response organization for each type of emergency
• Training programme for the responders
• Response arrangements
• Periodic review, update and test
Safety Aspects
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Conduct of Evaluation (cont.)
The regulatory body should be sure that the operator:
• Demonstrates the commitment of senior management to safety and the establishment and maintenance of a safety culture within the installation
• Demonstrates the implementation of an integrated approach to safety and security in the installation where radioactive waste are stored
Managerial Aspects
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Conduct of Evaluation (cont.)
The regulatory body should be sure that the operator:
• Applies an effective management system to all elements of radioactive waste storage. Features that are important for the safe operation of the facility or activity should be included on management system and identified in the safety assessment and supporting safety cases.
• Adequate human and financial resources
• Appropriate control (incl. (sub)contractors), etc.
• Safety Manuals, procedures, etc.
Managerial Aspects
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Conduct of Evaluation (cont.)
Safety Manual
• Selection of personnel, authorization and training
Qualification needed for important safety positions.
Plans for periodical education and training in
• Administrative regulations such as control of access to controlled zones
• Radiological monitoring of personnel and assessment of individual exposure
Identification of the personnel that need individual radiological surveillance
Description of radiological surveillance services
Assessment methods and measures to be adopted if reference levels are exceeded….
Managerial Aspects
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Conduct of Evaluation (cont.)
• Shutdown and Decommissioning
Final disposal arrangements in place
New facility allows for closing of an existing one
• Decommissioning plan
Decontamination and dismantling
Endpoint (unrestricted or restricted use)
Safety assessment for dismantling
Management of waste to be generated in operations
Verification of final conditions of the facilities
• Authorization for release from regulatory control
With or no conditions (WS-G.5.1)
Specific Aspects
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Licensing decisions
Decisions:
• Granting license or refusal of a license
• Strong justification and clear basis
• Well documented
• All documentation maintained and recorded
• Dissemination of information to the relevant competent authorities
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Licence/Authorisation Content
• Basis Licence application (No., date, etc.)
Legal basis (Law, regulations)
Reviewed documents (SARs, limits and conditions, etc.)
On-site visit(s) (protocols, etc.)
• Facility New
Old (with or without a licence) – link to previous licence and conditions
• Authorized entity
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Licence/Authorisation Content
• Authorized activity Siting, design, upgrading, decommissioning, etc.
• Limits, conditions and controls e.g. WAC, periodic reassessment of safety, reporting
• Licence period Put into force, validity
• Registration Number and link to other licenses
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After Granting an Authorisation
• Regulatory control of operation
Inspection
Review and evaluation of safety documents (SA, etc.)
• Periodic safety review (peer reviews)
• Licence modifications (structures, systems and
components, operational limits…)
Established review and approval procedure and
procedure for licence amendment
Dealt with same technical rigor as original licensing
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After Granting an Authorisation (cont.)
• Renewal of licence
Normal licensing procedure, with operational experience and updated documents
• Licence withdrawal
Serious violations of safety requirements, criteria
Serious violation of licence conditions
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Licensing Procedure
Further Regulatory Actions
Are there any regulatory actions after the licence
is granted?
• Inspections • Review and evaluation of safety • Periodic safety review • Modifications (SSC, operational limits..)
Established review and approval procedure or licence amendment
Dealt with same technical rigor as during licensing
• Update / Renewal of licence Normal licensing procedure, with operational
experience and updated documents
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Termination of Authorization
• Termination of a licence Shutdown of facility (e.g. source removal) Completion of decommissioning
• Final decommissioning plan 2 y prior shutdown Strategy, criteria, end state, financial means, etc.
• Final survey report
• Financial means for implementation of controls
• Formal decision of the Regulatory Body Safety Guide WS-G-5.1
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License endorsement
• Responsibility rests with the license holder:
Operator;
Subcontracts another entity.
• Subject of amendment:
Based on results of reassessment;
Change of limits and conditions;
Safety related changes in design.
• Subject of withdrawal:
Violations of safety requirements, criteria;
Unfulfilled license conditions;
Subject of additional conditions, for example:
Periodic report describing accepted / managed waste,
More frequent monitoring of the site.
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Effective licensing • Clear procedure and allocation of responsibilities
• Open dialogue between operators and regulators starting before the formal submission
• Active commitment of both operator and regulator
• Consultation with the public and other stakeholders
• Emphasis: Graded approach
Clear review procedure
Justification and transperancy of decisions
Termination of licence and site relase criteria
Non-radiological aspects and security
Summary
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IAEA Thank you! 67
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