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Link to the study - European Parliament - Europa

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Nuclear Decommissioning: Management of Costs and Risks<br />

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4.6. REGULATORY APPROACH<br />

The identification of best practices has shown that decommissioning requires:<br />

An overall permit procedure on a more general base;<br />

Close supervision and regula<strong>to</strong>ry procedures <strong>to</strong> decide on <strong>the</strong> sub-project level;<br />

Close communication of plans in early stages;<br />

Integration of licensing miles<strong>to</strong>nes and regula<strong>to</strong>ry approval times in <strong>the</strong> overall project plan.<br />

Failures <strong>to</strong> achieve <strong>the</strong>se objectives can cause serious delays and additional costs.<br />

4.6.1. Regula<strong>to</strong>ry approach in <strong>the</strong> decommissioning projects<br />

Bulgaria<br />

Bulgaria’s regula<strong>to</strong>ry agency BNRA has regulated <strong>the</strong> safety aspects of decommissioning already in<br />

2004, mainly dealing with <strong>the</strong> issue of still needed safety systems (BNRA 2004). The requirements for<br />

achieving a decommissioning license were later regulated, as Safety Guide (BNRA 2010). DP RAO<br />

applied in 2012 for this license:<br />

'In June 2012 SD RAW submitted applications <strong>to</strong> NRA for issuance of licenses for decommissioning of<br />

Unit 1 and Unit 2 of Kozloduy NPP. As a result of <strong>the</strong> review of <strong>the</strong> enclosed documents, it was<br />

assessed that a part of <strong>the</strong> presented documents need fur<strong>the</strong>r development, in order <strong>to</strong> satisfy <strong>the</strong><br />

legislative requirements for justification of main activities upon decommissioning.' (BNRA 2012)<br />

Also still pending is <strong>the</strong> regulation for wastes and for releasing wastes from regula<strong>to</strong>ry control<br />

(ANNEX 3, page 156).<br />

The relationships between <strong>the</strong> opera<strong>to</strong>r and <strong>the</strong> regula<strong>to</strong>ry body are described in ANNEX 3 as 'clear,<br />

well regulated' and 'based on mutual confidence'.<br />

Lithuania<br />

The Lithuanian regula<strong>to</strong>ry body VATESI has issued its regulation on decommissioning in 1999<br />

(VATESI 1999). In accordance with respective international safety requirements in IAEA 1999 this<br />

regulation called for a decommissioning plan for <strong>the</strong> facility, <strong>to</strong> be updated every three years.<br />

The current plan was provided for regula<strong>to</strong>ry approval last year:<br />

'In 2012, <strong>the</strong> updated Final Decommissioning Plan of Ignalina NPP was submitted for review by<br />

VATESI. Ignalina NPP is planning <strong>to</strong> revise <strong>the</strong> plan and <strong>to</strong> resubmit it for review by VATESI in 2013.'<br />

(VATESI 2012)<br />

The regula<strong>to</strong>ry framework of <strong>the</strong> decommissioning project is seen by <strong>the</strong> regula<strong>to</strong>ry body in a seven<br />

stage process, completely depending from <strong>the</strong> fuel unloading process, see Figure 38.<br />

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