Legal Aspects Issues for SMR Deployment in Indonesia
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1 INPRO Dialogue forum Vienna, Austria, October 2016 Legal Aspects Issues for SMR Deployment in Indonesia Bambang Eko Aryadi Directorate of Nuclear Installation & Material Regulation Development Nuclear Energy Regulatory Agency of INDONESIA (BAPETEN)
2 OUTLINES Introduction Regulatory framework Legal aspect issues Possible regulation development Activities Summary 24/10/16 2
3 INTRODUCTION Indonesia consists of around 17,500 big, medium and small islands, the big islands are: Java, Sumatra, Kalimantan, Sulawesi and Papua. Population is around 250 millions people with rate of 1.21% (2015) Total area of 1.9 million square miles including the ocean At the end of 2015, electrification ratio around 86,20% (not included non-pln customer) High demand and supply of energy in the future 3 DETIKFINANCE.COM, Friday (30/10/2015)
4 LONGTERM SOLUTION AND OBSTACLES Increase the electrification ratio through the 35,000 MW mega power plant project. Gas-based power plants were set to contribute 25 percent of the total capacity produced. State-owned electricity company (PT. PLN) has warned of a future gas supply deficit for the country, in the wake of rapidly increasing demand for the commodity following the growing number of gas-based power plants to be built in the national 35,000 megawatt (MW) project. In 2016 Java and Bali will experience a gas deficit of 118 billion British thermal units per day (Btu/d) Gas supply deficit is estimated to reach 281 Btu/d in 2017, and grow exponentially to 1,081 Btu/d in The deficit is then predicted to double and pass beyond 2,000 Btu/d in
5 CRASH PROGRAM Use 6 units marine vessel power-plant, owned by Turkish Karpowership Inauguration the use of first floating power plant (the Karadeniz Powership Zeynep Sultan) for the central and northern areas of Sulawesi was done in 8 dec 2016 The Karadeniz Powership Zeynep Sultan has a capacity to produce 120 MWe 5
6 SMR FOR INDONESIA BATAN promote the potency/advantages of SMR to overcome the problem of electricity in Indonesia Through an open-bidding, an experimental HTR-type SMR was selected in March Feasibility study and preparing conceptual design for Experimental Power Reactor of around 10 MWth in Serpong area. This reactor is planned to be operational in Licensing Progress: BATAN already submit application to get site license Licensing Directorate BAPETEN in the process of Evaluating Management System Implementation Report 6
7 ACT GOV. REGULATION Regulatory Framework BAPETEN CHAIRMAN REGULATIONS As July 2016 GR No.8 Year 2015 Safety Transport of Radioactive Source BCR No.5 Year 2007 Site Evaluation for Nuclear Installation NS-R-3 (being revised) BCR No.3 Year 2011 Safety for NPP Design NS-R-1 (being revised) BCR No.3 Year 2009 Operation Limit & Condition and Operating Procedures For NPP NS-G-2.2 Act No GR No.61 Year 2013 Radioactive Waste Management GR No.2 Year 2014 Licensing of Nuclear Inst & NM Utilization BCR No.8 Year 2013 Seismic aspect of Site Evaluation for NI BCR No.5Year 2015 Volcano aspect of Site Evaluation for NI BCR No.3 Year 2008 Dispersion of Radioactive Material in Air And Water and Consideration of Population Distribution in Site Evaluation For NPP NS-G-3.2 BCR No.4 Year 2008 Geotechnical Aspect of Site Evaluation and Foundation for NPP NS-G-3.6 (being revised) BCR No.6 Year 2012 Software for Computer Based System Important to Safety in NPP NS-G-1.1 BCR No.3 Year 2010 Design of Fuel Handling and Storage System For NPP NS-G-1.4 BCR No. 1 Year 2012 Protection Against Internal Fires and Explosion In the Design of NPP NS-G-1.7 BCR No.7 Year 2011 Design of Emergency Power System for NPP NS-G-1.8 BCR No.4 Year 2009 Decommissioning of Nuclear Reactor WS-G-2.1 OPERATION GR No.33 Year 2007 Safety of Ionizing Radiation & Security of radioactive sources GR No.29 Year 2008 Licensing the use of Ionizing Radiation Sources and Nuclear Materials GR No.27 Year 2009 Types and Tariff of Non-Tax State Revenues Applicable On BAPETEN BCR No.6 Year 2014 Meteorological & Hydrology aspect of Site Evaluation for NI BCR No.6 Year 2008 External Human Induce Event in Site Evaluation for NPP NS-G-3.1 BCR No.6 Year 2014 Meteorological and Hydrological Hazards in Site Evaluation for Nuclear Installations Series No. SSG-18 SITING BCR No.2 Year 2012 Protection against Internal Hazard Other Than Fire and Explosion Design of NPP NS-G-1.11 GS-G-4.1 Format and Content of SAR for NPP SSG-30 Safety Classification of SSC s in NPP DESIGN Legend GR No.46 Year 2009 Limit of Nuclear Liability In Planning In Preparation GR No.54 Year 2012 Safety & Security of Nuclear Installation SSG-38 Construction for Nuclear Installations In Reviewing Process Published
8 RELATED BAPETEN CHAIRMAN REGULATION (BCR) BCR No. 1 Year 2015 on Management of Emergency Respons of BAPETEN. BCR No. 1 Year 2010 on Nuclear Emergency Responses and Preparedness BCR No. 14 Year 2007 on Emergency Response Unit BCR No. 3 Year 2014 on Composing Document of Analysis for Enviromental Impact of Nuclear Energy Field BCR No. 7 Year 2013 on Dose Limit for Environmental Radioactivity BCR No. 6 Year 2013 on Working License for Operator of Installation and Nuclear Material BCR No. 6 Year 2010 on the Health Monitoring for Radiological Workers BCR No. 2 Year 2009 on the Making of Design Information List (DIQ) BCR No. 4 Year 2011 on the Safeguard System BCR No. 1 Year 2009 on the Physical Protection System Provision for Nuclear Installations and Materials BCR No. 9 Year 2006 on Additional Protocol to The System of Accountability and Control of Nuclear Material BCR No. 4 Year 2010 on the Management System of Nuclear Energy Facility and Utilization Activity BCR No. 4 Year 2009 on the Decommissioning of Nuclear Reactor
9 GOVERNMENT REGULATIONS No. 2/2014 LICENSING APPLICATIONS Doc.for Site Evaluation Approval : 1. Site Evaluation Program 2. Site Evaluations Management System Doc. Site Permit : 1. Site Evaluation Implementation Report 2. Management System Implementation Report 3. DIQ 4. Nuclear Reactor main Data Doc. For Design Approval: 1. Detail Design Document 2. Safety Analysis Report Doc. Construction License: 1. Safety Analysis Report 2. LCO Document 3. Management System Document 4. Radiation Protection and Safety Doc. 5. Safeguard System Doc 6. Physical Protection Plan Doc 7. Ageing Management Doc 8. Decommissioning Program 9. Emergency Preparedness Program 10. Construction Program 11. Environmental Impact License Doc. Commissioning License: 1. Safety Analysis Report 2. LCO Document 3. Management System Document 4. Radiation Protection and Safety Doc. 5. Safeguard System Doc 6. Physical Protection Plan Doc 7. Ageing Management Doc 8. Decommissioning Program 9. Emergency Preparedness Program 10. Construction Activity Report 11. Environmental Impact License 12. Technical Specification of Reactor that had been build. Doc. Operation License: 1. Safety Analysis Report 2. LCO Document 3. Maintenance Document 4. Radiation Protection and Safety Doc. 5. Safeguard System Doc 6. Physical Protection Plan Doc 7. Decommissioning Program 8. Emergency Preparedness Program 9. Management System Document 10. Environmental Impact License Implications Report Site Evaluation Approval Applications Design Approval Applications Operations License Applications Site Permit Applications Commissioning License Applications Reacto r Year Construction Activity Site Evaluations Approval Design Approval Construction License Commissioning License Operation License Site License Constructions License Applications
10 LEGAL ASPECTS ISSUES The key infrastructure issues for SMR deployment in Indonesia is gap of legal, regulation and institutional aspect to introduce various type of SMR. Currently most of the regulation is just applicable for large light water reactor with the land site basis. Goverment Regulation (GR) No.2/2014 on Licensing of Nuclear Installation & Nuclear Materials Utilization is for land base nuclear installation à article 1, site definition; BAPETEN Chairman Regulation (BCR) No.3/2011 on Safety of Power Reactor Design for land base Power Reactor and using light water cooling à article 3 No stipulate provision on graded approach 10
11 LEGAL ASPECTS ISSUES Issues related to floating NPP: Fabrication of the vessel replacement vessel after several years of operation 11
12 POSSIBLE REGULATION DEVELOPMENT To identify infrastructure issues for the deployment of SMR in Indonesia, BAPETEN conduct gap analysis 1. Cooperation with Faculty of Engineering University of Gadjah Mada: a. Assessment of Bapeten Chairman Regulation No.3/2011 on the Safety of Power Reactor Design à May 26, October 30, 2015; b. Assessment of Safety And Security Technology of the floating nuclear power plant à March 18, October 31, Cooperation with Faculty of Mathematics and Natural Sciences, Bandung Institute of Technology: Assessment of Safety And Security Technology of the Molten Salt Reactor à June 2016 November 2016 Supervision from GRS - Germany in establishing new BCR on design safety provision for power reactor à Under cooperation with European Union. 12
13 ASSESSMENT OF BCR No 3/2011 Bapeten Chairman Regulation (BCR) No.3/2011 on the Safety of Power Reactor Design was adopted from IAEA Safety Standards Series No. NS-R-1 in Safety Standards Series No. NS-R-1 has been revised by the IAEA became IAEA Safety Standards Series No. SSR-2/1 in A fundamental change in the SSR-2/1 is the related provisions of the basic design that includes a severe accident. These changes affect the sequence and contents of the requirements therein. à BCR No. 3/2011 requires mayor change 13
14 ASSESSMENT OF BCR No 3/2011 Some requirements need to be adjusted Need addi>onal emphasis on the safety aspects of some of these requirements, as in the following : The management of safety during the design: all the requirements have been appropriate. The main technical requirements à need adjustments related to the development of safety features for design extension condi>ons. Power reactors design in general: need some adjustments, par>cularly related to some terminologies in order to include HTR technology and some safety emphasis, such as the mel>ng of the core and the design extension condi>ons. Need a big change related to the shared use of safety system among the mul> unit for the design extension condi>ons. Power reactors system design in par>cular: need a few adjustment, par>cularly related to some terminologie in order to include HTR technology and some safety emphasis. In order to be able to an>cipate HTR technological developments and safety requirements aner the fukushima accident, the all things men>oned above should be concider in revising BCR no. 3 of 2011 on the design safety provision for power reactor 14
15 ASSESSMENT OF BCR No 3/2011 Req. IAEA SSR-2/1 No. Requirement RecommendaDon 16 Postulated ini>a>ng Need to consider the specific terminology for HTR events 19 Design basis accidents Changing LOCA with DBA for HTR (eg depressuriza>on, air / water ingress) 20 Design extension consider specific DEC for HTR condi>ons 40 Preven>on of harmful interac>ons of systems important to safety Part (5.70) which states "fluid system" for LWR needs to be replaced with more common "fluid system" 43 Performance of fuel elements and assemblies terminology fuel elements and assemblies need to adjusted with HTR fuel 46 Reactor shutdown HTR control system is a graphite sleeve contains boron. liquid for Reac>vity control (boric acid) can not apply to HTR 15
16 ASSESSMENT OF SAFETY AND SECURITY TECHNOLOGY OF THE FLOATING NPP Scope of the assessment: Technical design Site selection Safety Impact on environmental Nuclear safety Legal aspects Institutions involved: Surabaya Institute of Technology (ITS) and PT. PAL (Indonesian Shipyard) 16
17 LEGAL ASPECT FOR SITE LICENSE No. Technical provisions Related Regulations Result 1 implementation of Site Evaluation BCR No.3 Year 2008 on Dispersion of Radioactive Material in Air And Water and Consideration of Population Distribution in Site Evaluation For NPP (IAEA NS-G-3.2) Can be fully applied for location near the coast (onshore). 2 Site Evaluation Management System BCR No.4 Year 2008 on Geotechnical Aspect of Site Evaluation and Foundation for NPP (IAEA NS-G-3.6) à being revised BCR No.8 Year 2013 on Seismic aspect of Site Evaluation for NI BCR No.6 Year 2014 on Meteorological & Hydrology aspect of Site Evaluation for NI BCR No.5Year 2015 on Volcano aspect of Site Evaluation for NI BCR No.6 Year 2008 on External Human Induce Event in Site Evaluation for NPP (IAEA NS-G-3.1) BCR No. 4 Year 2010 on the Management System of Nuclear Energy Facility and Utilization Activity 3 DIQ BCR No. 2 Year 2009 on the Making of Design Information List (DIQ) 4 The main data of Nuclear Reactor Not available Not required Can be partially applied (for the location of the connecting facility on the mainland) Can be partially applied (hazards from extreme weather conditions : wind, waves, and tsunamis) Can be partially applied (burst hazard, tsunami) Need adjustments associated with hazard in the floating location. Can be fully applied Can be fully applied
18 ACTIVITIES Activities to enhance competence of BAPETEN staff : Dispatch BAPETEN staff to study regulation and licensing process of HTGR to Japan, China, Germany, and South Africa (2016); Dispatch BAPETEN staff to study HTGR safety analysis to Germany (2016); Dispatch BAPETEN staff to study regulation, licensing and technology of floating NPP to Russia (in planning). 18
19 SUMMARY SMR technology suitable for archipelagic country Currently most of the regulation is just can be implement for large light water reactor with the land site basis. BAPETEN has conducted a gap analysis for regulations related to nuclear power plant. The implementation of gap analysis hopefully will make regulations on Safety of Power Reactor Design can be implemented on all types of nuclear power plants 19
20 Thank You
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