Link to the study - European Parliament - Europa
Link to the study - European Parliament - Europa
Link to the study - European Parliament - Europa
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Nuclear Decommissioning: Management of Costs and Risks<br />
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Harmonisation with EU legislation (EURATOM Treaty, EC Directives) is maintained continuously – even<br />
latest Council Directive 2011/70/EURATOM for responsible and safe management of spent fuel and<br />
radioactive waste has been already fully incorporated in<strong>to</strong> Slovak legislation.<br />
Regula<strong>to</strong>ry bodies understand <strong>the</strong> complexity and <strong>the</strong> nature of NPP decommissioning. Their actions<br />
lead <strong>to</strong> finding solutions supporting successful continuance of decommissioning activities<br />
implementation in particular projects in accordance with all legal requirements.<br />
The only misunderstanding JAVYS has experienced is application of provisions from <strong>the</strong><br />
Environmental Impact Assessment (made in 2007) in discussions with <strong>the</strong> Ministry of Environment of<br />
<strong>the</strong> Slovak Republic. Therefore, <strong>to</strong> transparently cover <strong>the</strong> environmental issues, JAVYS has decided <strong>to</strong><br />
prepare a new full-scale EIA (due in 2014) for all <strong>the</strong> works necessary for successful decommissioning<br />
and site remediation (instead of preparing numerous small one-purpose individual EIAs).<br />
Any and all EIAs are prepared according <strong>to</strong> EBRD’s Environmental and Social Policies and under EBRD<br />
supervision, <strong>to</strong>o.<br />
Are <strong>the</strong> different roles of you as <strong>the</strong> opera<strong>to</strong>r and <strong>the</strong> regula<strong>to</strong>ry body clear for you (does <strong>the</strong><br />
regula<strong>to</strong>ry body remain in its own role, would you expect more assistance, etc.)?<br />
Roles and responsibilities of both, <strong>the</strong> opera<strong>to</strong>r and <strong>the</strong> regula<strong>to</strong>ry bodies are clearly defined and set<br />
by relevant legislation. Relationship and interactions between JAVYS and regula<strong>to</strong>ry bodies are<br />
transparent, cooperation and assistance on daily basis is correct and functional.<br />
In which fields could <strong>the</strong> regula<strong>to</strong>ry body ease your planning, technical and financial structures<br />
(should <strong>the</strong>re be more detailed regulation, should <strong>the</strong>re be more written regulation, etc.)?<br />
Legislation frame for decommissioning is well determined and clear, as well as fully in compliance<br />
with EU legislation and EURATOM.<br />
Is it difficult for you <strong>to</strong> understand <strong>the</strong> regula<strong>to</strong>ry issues?<br />
Regula<strong>to</strong>ry issues are defined well and clear and <strong>the</strong>y can be supported by interpretations if<br />
necessary. JAVYS is used <strong>to</strong> deal with <strong>the</strong> legislation for already a long time and it respects <strong>the</strong> needs<br />
and expectations of <strong>the</strong> regula<strong>to</strong>ry bodies. This can be seen on <strong>the</strong> results of audits performed by <strong>the</strong><br />
regula<strong>to</strong>ry bodies - having no major findings. Moreover, JAVYS actively participates on legislation<br />
elaboration by means of active cooperation during <strong>the</strong>ir preparation or review of <strong>the</strong>se documents<br />
before <strong>the</strong>ir final issue and adoption.<br />
How would you evaluate your relationship with <strong>the</strong> regula<strong>to</strong>ry body (cautious, trustfully,<br />
distantly, frustrating)?<br />
On <strong>the</strong> basis of abovementioned, we can summarize that relations with regula<strong>to</strong>ry bodies are<br />
professional and respecting principles of correct and open communication. The regula<strong>to</strong>rs are<br />
officially and regularly informed about <strong>the</strong> status of V1 NPP decommissioning projects on quarterly<br />
basis, as well as on ad hoc working meetings when needed.<br />
Thus, through <strong>the</strong> mechanisms of constant communication via various permanent meetings, or<br />
through cooperation with NRA’s locality inspec<strong>to</strong>r, permanently present on site, JAVYS has<br />
established a solid and effective lines of communication and thus of high-level trustful mutual<br />
relationship with <strong>the</strong> Nuclear Regula<strong>to</strong>ry Authority in Slovakia.<br />
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