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Policy Department D: Budgetary Affairs ____________________________________________________________________________________________ Additional smaller-scale facilities, storages and projects for management of increased volumes of materials are being implemented, or the current ones are being reconstructed, so they will be in operation during the respective phase of decommissioning Did missing waste management means delay or obstruct your technical or regulatory timeframe? This point is addressed above. We do not expect any serious set-backs or delays in dismantling & demolition projects implementation compared to time schedule set up in the Strategy of Bohunice V1 NPP Decommissioning. JAVYS has already built, or is building the necessary infrastructure. The latter projects shall represent supplementing of already existing RAW processing, storage and disposal infrastructure so that overall infrastructure is available before decommissioning projects producing waste are launched. If you see current or future difficulties with your long-term waste management, what will be the measures you see as promising to answer to that expectations? With respect to long-term Spent Nuclear Fuel management we share the same difficulties as other EU countries: no common policy has been passed on the European level on disposal of spent fuel in deep-geological repository. Slovak Republic has nevertheless elaborated feasibility studies for deep-geological repository to be located in the Slovak Republic and several potential locations have been identified. JAVYS perceives that only an official and unified policy on the erection of deep-geological repositories adopted at the European level would promote the European countries to erect these facilities on their territories. RAW coming from V1 NPP decommissioning and not immediately acceptable for disposal in the National Repository in Mochovce is planned to be stored in the Interim Storage at Jaslovske Bohunice nuclear site. Start of operation of Interim Storage is planned in 2016 and apart from storing middle level RAW, it will serve also as a decay storage in order to ensure maximum volumes of free released materials in next decades. Slovak Republic also operates a National Repository for low level waste and JAVYS has currently overcome major administrative obstacles for its enlargement for the purposes of decommissioning waste disposal, as well as erection of a very low level waste repository. Regulatory aspects Have you encountered difficulties caused by regulatory action so far in your project (major delays, necessary re-planning caused by regulation, difficulties in finding common understanding)? If so: what were the reasons for that in your view (incompetence, unwillingness, misunderstandings, etc.) In general, Slovakia has well drafted, long established and EU harmonised nuclear legislation which makes any nuclear licencing well predictable. The same applies also for the applications for decommissioning licence – although the scope and details of documents submitted were significant, the necessary documentation definition has been clearly written in the Atomic Law and its corresponding Decrees, issued by the Nuclear Regulatory Authority. 176
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________ Harmonisation with EU legislation (EURATOM Treaty, EC Directives) is maintained continuously – even latest Council Directive 2011/70/EURATOM for responsible and safe management of spent fuel and radioactive waste has been already fully incorporated into Slovak legislation. Regulatory bodies understand the complexity and the nature of NPP decommissioning. Their actions lead to finding solutions supporting successful continuance of decommissioning activities implementation in particular projects in accordance with all legal requirements. The only misunderstanding JAVYS has experienced is application of provisions from the Environmental Impact Assessment (made in 2007) in discussions with the Ministry of Environment of the Slovak Republic. Therefore, to transparently cover the environmental issues, JAVYS has decided to prepare a new full-scale EIA (due in 2014) for all the works necessary for successful decommissioning and site remediation (instead of preparing numerous small one-purpose individual EIAs). Any and all EIAs are prepared according to EBRD’s Environmental and Social Policies and under EBRD supervision, too. Are the different roles of you as the operator and the regulatory body clear for you (does the regulatory body remain in its own role, would you expect more assistance, etc.)? Roles and responsibilities of both, the operator and the regulatory bodies are clearly defined and set by relevant legislation. Relationship and interactions between JAVYS and regulatory bodies are transparent, cooperation and assistance on daily basis is correct and functional. In which fields could the regulatory body ease your planning, technical and financial structures (should there be more detailed regulation, should there be more written regulation, etc.)? Legislation frame for decommissioning is well determined and clear, as well as fully in compliance with EU legislation and EURATOM. Is it difficult for you to understand the regulatory issues? Regulatory issues are defined well and clear and they can be supported by interpretations if necessary. JAVYS is used to deal with the legislation for already a long time and it respects the needs and expectations of the regulatory bodies. This can be seen on the results of audits performed by the regulatory bodies - having no major findings. Moreover, JAVYS actively participates on legislation elaboration by means of active cooperation during their preparation or review of these documents before their final issue and adoption. How would you evaluate your relationship with the regulatory body (cautious, trustfully, distantly, frustrating)? On the basis of abovementioned, we can summarize that relations with regulatory bodies are professional and respecting principles of correct and open communication. The regulators are officially and regularly informed about the status of V1 NPP decommissioning projects on quarterly basis, as well as on ad hoc working meetings when needed. Thus, through the mechanisms of constant communication via various permanent meetings, or through cooperation with NRA’s locality inspector, permanently present on site, JAVYS has established a solid and effective lines of communication and thus of high-level trustful mutual relationship with the Nuclear Regulatory Authority in Slovakia. 177
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