legal aspects issues for smr deployment in indonesia

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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) INPRO Dialogue forum Vienna, Austria, 18 – 21 October 2016

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Page 1: Legal Aspects Issues for SMR Deployment in Indonesia

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)

INPRO Dialogue forum Vienna, Austria, 18 – 21 October 2016

Page 2: Legal Aspects Issues for SMR Deployment in Indonesia

•  Introduction •  Regulatory framework •  Legal aspect issues •  Possible regulation development •  Activities •  Summary

OUTLINES

24/10/16 2

Page 3: Legal Aspects Issues for SMR Deployment in Indonesia

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

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DETIKFINANCE.COM, Friday (30/10/2015)

Page 4: Legal Aspects Issues for SMR Deployment in Indonesia

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 2019. The deficit is then predicted to double and pass beyond 2,000 Btu/d in 2026

4 http://www.thejakartapost.com/news/2016/05/27/pln-warns-of-gas-deficit-due-to-35000-mw-project.html

Page 5: Legal Aspects Issues for SMR Deployment in Indonesia

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 http://www.thejakartapost.com/news/2015/12/09/power-plant-vessels-solve-energy-deficit-outer-regions.html

Page 6: Legal Aspects Issues for SMR Deployment in Indonesia

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 2015.

•  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 2021.

•  Licensing Progress: –  BATAN already submit application to get site license –  Licensing Directorate – BAPETEN in the process of Evaluating

Management System Implementation Report

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Page 7: Legal Aspects Issues for SMR Deployment in Indonesia

Act No.10 1997

GR No.46 Year 2009 Limit of Nuclear Liability

GR No.8 Year 2015 Safety Transport of Radioactive Source

GR No.61 Year 2013 Radioactive Waste

Management

GS-G-4.1 Format and Content of SAR for NPP

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.2 Year 2012 Protection against Internal Hazard Other

Than Fire and Explosion Design of NPP NS-G-1.11

BCR No.3 Year 2009 Operation Limit & Condition and Operating

Procedures For NPP NS-G-2.2

BCR No.3 Year 2011 Safety for NPP Design

NS-R-1 (being revised)

BCR No.6 Year 2008 External Human Induce Event in Site

Evaluation for NPP NS-G-3.1

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.6 Year 2014 Meteorological and Hydrological Hazards

in Site Evaluation for Nuclear Installations Series No. SSG-18

BCR No.4 Year 2008 Geotechnical Aspect of Site Evaluation and

Foundation for NPP NS-G-3.6

(being revised)

BCR No.4 Year 2009 Decommissioning of Nuclear Reactor

WS-G-2.1

BCR No.5 Year 2007 Site Evaluation for Nuclear Installation

NS-R-3 (being revised)

GOV. REGULATION BAPETEN CHAIRMAN REGULATIONS

Legend

In Preparation

In Reviewing Process

In Planning

Published

ACT As – July 2016

GR No.2 Year 2014 Licensing of Nuclear Inst &

NM Utilization

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

GR No.33 Year 2007 Safety of Ionizing Radiation &

Security of radioactive sources

BCR No.6 Year 2014 Meteorological & Hydrology aspect

of Site Evaluation for NI

BCR No.5Year 2015 Volcano aspect of Site Evaluation for NI

BCR No.8 Year 2013 Seismic aspect of Site Evaluation for NI

SITING

DESIGN

OPERATION

GR No.54 Year 2012 Safety & Security of Nuclear Installation

SSG-30 Safety Classification of SSC’s in NPP

SSG-38 Construction for Nuclear Installations

CONSTRUCTION

Regulatory Framework

Page 8: Legal Aspects Issues for SMR Deployment in Indonesia

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

Page 9: Legal Aspects Issues for SMR Deployment in Indonesia

Year

Reacto

r

Site Permit Applications

Site License

Construction License

Commissioning License Operation License

Commissioning License Applications

Operations License Applications

Construction Activity

GOVERNMENTREGULATIONSNo.2/2014LICENSINGAPPLICATIONS

Design Approval Applications

Site Evaluation Approval Applications

Site Evaluations Approval

Design Approval

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

Constructions License Applications

Page 10: Legal Aspects Issues for SMR Deployment in Indonesia

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

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Page 11: Legal Aspects Issues for SMR Deployment in Indonesia

LEGAL ASPECTS ISSUES

Issues related to floating NPP: •  Fabrication of the vessel •  replacement vessel after several years of operation

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Page 12: Legal Aspects Issues for SMR Deployment in Indonesia

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, 2015 - October 30, 2015;

b.  Assessment of Safety And Security Technology of the floating nuclear power plant à March 18, 2016 - October 31, 2016

2.  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.

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Page 13: Legal Aspects Issues for SMR Deployment in Indonesia

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 2000.

•  Safety Standards Series No. NS-R-1 has been revised by the IAEA became IAEA Safety Standards Series No. SSR-2/1 in 2012.

•  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

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Page 14: Legal Aspects Issues for SMR Deployment in Indonesia

ASSESSMENT OF BCR No 3/2011

•  Somerequirementsneedtobeadjusted•  Needaddi>onalemphasisonthesafetyaspectsofsomeof theserequirements,as in

thefollowing:–  The management of safety during the design: all the requirements have been

appropriate.–  Themaintechnicalrequirementsàneedadjustmentsrelatedtothedevelopment

ofsafetyfeaturesfordesignextensioncondi>ons.–  Powerreactorsdesigningeneral:needsomeadjustments,par>cularly relatedto

someterminologiesinordertoincludeHTRtechnologyandsomesafetyemphasis,suchasthemel>ngofthecoreandthedesignextensioncondi>ons.

–  Needabigchangerelatedtotheshareduseofsafetysystemamongthemul>unitforthedesignextensioncondi>ons.

–  Power reactors system design in par>cular: need a few adjustment, par>cularlyrelatedtosometerminologieinordertoincludeHTRtechnologyandsomesafetyemphasis.

•  In order to be able to an>cipate HTR technological developments and safetyrequirementsaNerthefukushimaaccident, theallthingsmen>onedaboveshouldbeconciderinrevisingBCRno.3of2011onthedesignsafetyprovisionforpowerreactor

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Page 15: Legal Aspects Issues for SMR Deployment in Indonesia

ASSESSMENT OF BCR No 3/2011

Req.No.

IAEASSR-2/1Requirement RecommendaDon

16 Postulatedini>a>ngevents

NeedtoconsiderthespecificterminologyforHTR

19 Designbasisaccidents ChangingLOCAwithDBAforHTR(egdepressuriza>on,air/wateringress)

20 Designextensioncondi>ons

considerspecificDECforHTR

40 Preven>onofharmfulinterac>onsofsystemsimportanttosafety

Part(5.70)whichstates"fluidsystem"forLWRneedstobereplacedwithmorecommon"fluidsystem"

43 Performanceoffuelelementsandassemblies

terminologyfuelelementsandassembliesneedtoadjustedwithHTRfuel

46 Reactorshutdown HTRcontrolsystemisagraphitesleevecontainsboron.liquidforReac>vitycontrol(boricacid)cannotapplytoHTR

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Page 16: Legal Aspects Issues for SMR Deployment in Indonesia

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)

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Page 17: Legal Aspects Issues for SMR Deployment in Indonesia

LEGAL ASPECT FOR SITE LICENSE

No. Technical provisions Related Regulations Result1 implementation of

Site EvaluationBCR 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).

BCR No.4 Year 2008 on Geotechnical Aspect of Site Evaluation and Foundation for NPP (IAEA NS-G-3.6) à being revised

Not required

BCR No.8 Year 2013 on Seismic aspect of Site Evaluation for NI

Can be partially applied (for the location of the connecting facility on the mainland)

BCR No.6 Year 2014 on Meteorological & Hydrology aspect of Site Evaluation for NI

Can be partially applied (hazards from extreme weather conditions : wind, waves, and tsunamis)

BCR No.5Year 2015 on Volcano aspect of Site Evaluation for NI

Can be partially applied (burst hazard, tsunami)

BCR No.6 Year 2008 on External Human Induce Event in Site Evaluation for NPP (IAEA NS-G-3.1)

Need adjustments associated with hazard in the floating location.

2 Site Evaluation Management System

BCR No. 4 Year 2010 on the Management System of Nuclear Energy Facility and Utilization Activity

Can be fully applied

3 DIQ BCR No. 2 Year 2009 on the Making of Design Information List (DIQ)

Can be fully applied

4 The main data of Nuclear Reactor

Not available

Page 18: Legal Aspects Issues for SMR Deployment in Indonesia

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).

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Page 19: Legal Aspects Issues for SMR Deployment in Indonesia

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

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